In re A.M. CA2/1, B268136

On June 13, 2015, Father and 17-year-old A.M. (Minor) had a physical altercation over Father’s cell phone; Father suffered a scratch to his upper lip that bled.
Police responded; both appeared upset and Minor told officers she was a heroin user and becomes emotional while withdrawing; she said she tried to take the phone back and accidentally scratched Father.
Father testified Minor pounded his back and then made semi-circular punching motions; one punch struck his face below the nose and above the right side of his lip, drawing blood.
Minor’s trial testimony largely matched her statements at the scene but she added claims that Father pushed and then beat her; those additional allegations were not mentioned to the arresting officer.
The juvenile court sustained a Welfare & Institutions Code section 602 petition alleging misdemeanor battery (Pen. Code § 242) and placed Minor in probation custody for up to six months; Minor appealed, challenging sufficiency of the evidence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether there was substantial evidence to sustain a misdemeanor battery adjudication	The People argued evidence showed Minor willfully used force that caused Father’s injury	Minor argued the contact was accidental while reaching for the phone and lacked the willful intent required for battery	The court held substantial evidence supported willful use of force and affirmed the adjudication

In re Matthew A., 165 Cal.App.4th 537 (2008) (same substantial-evidence standard applies in juvenile and adult cases)
People v. Bolin, 18 Cal.4th 297 (1998) (reversal unwarranted unless no hypothesis supports the conviction)
People v. Shockley, 58 Cal.4th 400 (2013) (any harmful or offensive touching can constitute battery)
People v. Colantuono, 7 Cal.4th 206 (1994) (battery is a general intent crime; intent to do the act suffices)
In re James B., 109 Cal.App.4th 862 (2003) (appellate court cannot substitute its inferences for those of the factfinder)