Reginald K. Teneyck v. United States, 112 A.3d 906

Teneyck convicted of assault-related offenses after January 2011 attempted robbery near Dupont Circle.
Appellant challenges sufficiency of evidence for felony (significant bodily injury) and fairness of sentence.
Injury at issue: cuts to the complainant’s hands from broken glass; no clear evidence of hospitalization.
Trial record lacked medical witnesses; EMTs and doctors’ reports were admitted as exhibits.
Court held: injuries not shown to require hospitalization or immediate medical attention; insufficient for significant bodily injury.
Remand ordered: acquittal of felony assault count with resentencing guided by the judgment of acquittal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether McDonough’s hand injuries were a significant bodily injury.	Teneyck argues injuries were not significant under §22-404(a)(2).	Government contends injuries were significant due to hospital/medical treatment.	Insufficient evidence; injuries not significant under statute.
Whether medical treatment implies significance under Quintanilla and Nero.	McDonough’s hospital visit and incision imply significance.	Treatment alone does not prove significance; must be necessary to prevent long-term damage.	Treatment did not establish immediate medical attention required to be significant.
Whether sentencing relied on unreliable rumors or hearsay.	Teneyck argues sentencing relied on untrustworthy rumors about auto theft.	Judge relied on presentence report and questioned officers; relied less on rumors.	No due process violation; court relied on presentence history and discounted officer testimony.
Whether the sentencing judge’s use of rumor evidence violated due process.	Unreliable evidence tainted sentencing.	Evidence scrutinized; not reasonably relied upon in sentencing.	No significant possibility of reliance on unreliable information; due process not violated.
Disposition on remand and consequences for the conviction.			Remand with instruction to vacate felony assault conviction and resentence accordingly.

Nero v. United States, 73 A.3d 153 (D.C. 2013) (definition of significant bodily injury; need for immediate medical attention)
Quintanilla v. United States, 62 A.3d 1261 (D.C. 2013) (injury not significant if treatable with self-administered remedies)
In re R.S., 6 A.3d 854 (D.C. 2010) (significant injury criteria; long-term damage focus)
James v. United States, 39 A.3d 1262 (D.C. 2012) (limits on inference; no speculation for criminal conviction)
Jackson v. United States, 940 A.2d 981 (D.C. 2008) (infection risk as insufficient for significant injury)
Flores v. United States, 37 A.3d 866 (D.C. 2011) (stitches and treatment context; not necessarily significant injury)
Martin v. Gentile, 849 F.2d 863 (4th Cir. 1988) (pain level not sufficient for significant injury)
Brown v. United States, 464 A.2d 120 (D.C. 1983) (remedial considerations on remand for lesser included offense)