Morris Eugene Grimes v. The State of Wyoming, 304 P.3d 972

On Feb 26, 2012, Gillette officers responded to a disturbance at a motel involving Morris Grimes arguing over bus transportation.
Officers arrested Grimes for breach of the peace, handcuffed him, and tried to place him in a patrol car after repeated noncompliance.
Grimes resisted, was tased to gain compliance, then moved his hands and kicked inside the patrol car; officers removed him from the vehicle.
When the door opened, Grimes kicked Officer Kimberling in the chest; Kimberling fell onto asphalt and later developed lower back pain, sought ER treatment, and missed work.
Grimes was convicted by a jury of felony interference with a peace officer (Wyo. Stat. § 6-5-204(b)); he appealed arguing the State failed to prove he caused bodily injury to the officer.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was there sufficient evidence that Grimes caused bodily injury to a peace officer under § 6-5-204(b)?	State: Officer Kimberling’s testimony and vehicle recordings support the inference that Grimes’ kick caused Kimberling to fall and later suffer back pain.	Grimes: Officer initially said he was unhurt; no medical evidence tying delayed back pain to the fall; other intervening causes possible.	The court affirmed: the jury could reasonably infer Grimes’ kick was the proximate cause of the officer’s bodily injury based on testimony and recordings.

Allen v. State, 43 P.3d 551 (Wyo. 2002) (proximate-cause/substantial-factor standard for causation).
Seeley v. State, 959 P.2d 170 (Wyo. 1998) (definition and evidentiary role of permissible inferences).
Anderson v. State, 216 P.3d 1143 (Wyo. 2009) (standard for reviewing sufficiency of evidence; view State’s evidence and reasonable inferences in favor of verdict).
Mascarenas v. State, 76 P.3d 1258 (Wyo. 2003) (testimony of pain can satisfy statutory “bodily injury” element).
Hulsy v. State, 209 P.3d 901 (Wyo. 2009) (alternative means of causing officer injury still satisfy interference statute).