Dominic A. White v. United States, 207 A.3d 580

Haynes filed an insurance claim for stolen rims/tires with doctored receipts; State Farm suspected fraud and investigated. Texts and calls linked White to preparing receipts.
Haynes confronted Philip Lovell at WTF Towing lot; White arrived, struck Lovell twice in the head with an aluminum pole, then fled. Lovell was bleeding, disoriented, and transported to the ER.
ER CT scan showed no acute brain injury; Lovell had two ~4 cm scalp lacerations closed with 18 staples, received pain medication, and was discharged the same night. He later suffered migraines for months and saw a neurologist who found a normal exam.
Haynes was convicted of insurance fraud and conspiracy (no appeal). White was convicted of insurance fraud, conspiracy, aggravated assault while armed (AAWA), assault with a dangerous weapon (ADW), and prohibited-weapon possession; sentenced to concurrent and consecutive terms.
On appeal White challenged jury instruction responsiveness, sufficiency of evidence for insurance fraud and for AAWA (serious bodily injury standard). Court affirmed fraud convictions, vacated AAWA, entered judgment for lesser-included ASBI while armed, affirmed other convictions, and remanded for resentencing.

Issue	Plaintiff's Argument (White)	Defendant's Argument (Government)	Held
Whether judge erred in answering jury note about the pole	Judge should have told jury the pole in evidence must be the weapon	Government: need only prove object was a pole/dangerous weapon; exact exhibit need not be the weapon	No error — jury need not find the exhibit was the exact pole, only that the object was a pole and a dangerous weapon
Sufficiency of evidence for insurance fraud and conspiracy	White was an unwitting participant; insufficient proof linking him to doctored receipts	Texts/emails and a call from appellant’s number show he helped create receipts and participated	Affirmed — evidence viewed favorably to prosecution was sufficient
Whether evidence showed "serious bodily injury" for AAWA	Lovell experienced extreme pain and protracted migraines — supports serious bodily injury	Government relied on scalp lacerations, CT scan, staples, and ongoing migraines as indicia of serious injury	Reversed AAWA conviction — record insufficient to prove "serious bodily injury" under Nixon standard
Whether evidence supports lesser-included ASBI while armed	ASBI requires hospitalization or immediate medical attention; argues insufficient	Government: CT scan, cleaning, anesthesia, staples, and medical testimony that prompt treatment was required show immediate professional care	Affirmed entry of judgment for ASBI while armed — injuries warranted immediate medical attention and trained treatment

Nixon v. United States, 730 A.2d 145 (definition and high threshold for "serious bodily injury")
Swinton v. United States, 902 A.2d 772 (examples of injuries meeting serious bodily injury standard)
Jackson v. United States, 940 A.2d 981 (superficial lacerations and non-extreme pain; AAWA vacated)
Bolanos v. United States, 938 A.2d 672 (stabbing with hospitalization supporting extreme pain)
Jenkins v. United States, 877 A.2d 1062 (stabbings requiring surgery and prolonged hospitalization)
Cheeks v. United States, 168 A.3d 691 (jury communication standard; also ASBI/ADW analysis)
Nero v. United States, 73 A.3d 153 (distinguishing significant bodily injury where medical treatment was necessary)
Quintanilla v. United States, 62 A.3d 1261 (minor injuries treatable with basic remedies not "significant")
Belt v. United States, 149 A.3d 1048 (medical treatment required to prevent long-term damage qualifies as "significant")