Quintanilla v. United States
2013 D.C. App. LEXIS 80
| D.C. | 2013Background
- Appellant was convicted after a jury trial of multiple crimes arising from a robbery at Connecticut Ave and K St NW.
- Appellant challenges only the felony assault conviction, arguing Roth did not suffer a significant bodily injury.
- Roth sustained head and hand injuries, with headaches for about a week and a half and fingers swollen for about three weeks; index finger nearly unusable for two months.
- EMTs examined Roth at the scene and provided cold compresses but no medical treatment or hospital transport.
- Roth declined hospital transportation due to lack of health insurance and because she believed the injuries were not serious.
- The trial court submitted felony assault to the jury; the appellate court reverses and remands for simple assault due to insufficient evidence of significant bodily injury.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Roth's injuries meet significant bodily injury | Ferren argues injuries required hospitalization or immediate medical attention. | Ferren contends injuries do not meet the standard for significant bodily injury. | No; injuries not significant; remand for simple assault. |
| Whether medical attention was necessary to qualify as significant bodily injury | Roth's treatment context supports significant injury. | Lack of professional medical treatment shows no significant injury. | Not significant; treatment must be medical and prevent long-term harm. |
| Application of the 'significant bodily injury' test to the facts | Jury could find significant injury from head/hand trauma. | No long-term consequences or hospitalization; not significant. | Objectively, injuries did not require hospitalization or immediate medical treatment; convict for simple assault only. |
Key Cases Cited
- In re R.S., 6 A.3d 854 (D.C.2010) (significant injury requires prompt medical attention; not equal to mere diagnosis)
- In re R.P., 136 Daily Wash. L. Rptr. 549 (D.C.2008) (definition of attention as treatment to preserve health; latent injuries discussed)
- Nixon v. United States, 730 A.2d 145 (D.C.1999) (use of serious bodily injury definition for aggravated assault context)
- Earle v. United States, 612 A.2d 1258 (D.C.1992) (treatment as medical attention discussed in context of bodily injury)
- Lewis v. United States, 767 A.2d 219 (D.C.2001) (standards for appellate review of sufficiency of evidence)
- Colter v. United States, 37 A.3d 282 (D.C.2012) (contextual discussion of bodily injury definitions)
- Flores v. United States, 37 A.3d 866 (D.C.2011) (example of evaluating 'reckless' conduct in felony assault context)