State of Minnesota v. Esteban Perez-Juarez, A15-1873

At a college party, an intoxicated student, D.R., passed out in his bedroom. Later, a short Hispanic man was seen with his pants down between D.R.’s legs; the man left when observed.
The man returned, attempted to re-enter the house, and was later identified by his phone as Esteban Perez-Juarez.
D.R. woke the next morning with soreness in his anus and abrasions on his upper right back/shoulder; a hospital sexual-assault exam collected swabs.
Forensic testing found semen with a DNA mixture; Perez-Juarez could not be excluded as a contributor to the minor profile.
Perez-Juarez was charged with multiple counts of criminal sexual conduct; a jury convicted him of second- and fourth-degree CSC but acquitted him of first- and third-degree counts.
On appeal Perez-Juarez argued insufficient evidence that he caused D.R. to suffer "personal injury," required for second-degree CSC; the district court had denied his motion for acquittal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether evidence proved "personal injury" for second-degree CSC	State: D.R.’s reported soreness and observed abrasions satisfy "personal injury."	Perez‑Juarez: Pain was minimal/short-lived and lacked objective signs like bruising, tearing, or bleeding.	Affirmed: physical pain and abrasions were sufficient to prove personal injury.

State v. Ortega, 813 N.W.2d 86 (Minn. 2012) (standard for reviewing sufficiency-of-evidence claims)
State v. Johnson, 152 N.W.2d 768 (Minn. 1967) (physical pain alone can satisfy "personal injury")
State v. Reinke, 343 N.W.2d 660 (Minn. 1984) (abrasion and pain can establish personal injury)
State v. Dooley, 380 N.W.2d 582 (Minn. App. 1986) (nonpermanent physical injuries supported second-degree CSC conviction)
State v. Jarvis, 665 N.W.2d 518 (Minn. 2003) (a minimal amount of physical pain or injury is sufficient)