State of Minnesota v. John Ishmael Bradley, III, 4 N.W.3d 105

John Ishmael Bradley, III struck his girlfriend, R.C., on the head with a broom handle during an argument, causing a significant head injury that required seven stitches.
The State of Minnesota charged Bradley with second-degree assault with a dangerous weapon and felony domestic assault.
At trial, the jury found Bradley guilty on both counts, and the district court entered convictions for both but imposed a sentence only on the second-degree assault.
Bradley appealed, arguing the broom handle was not a dangerous weapon under the statute and that convicting him of both offenses arising from the same act was improper.
The Minnesota Court of Appeals affirmed both convictions; Bradley petitioned for, and was granted, further review by the Minnesota Supreme Court.

Issue	Bradley's Argument	State's Argument	Held
Was the broom handle a "dangerous weapon" under the manner-of-use definition?	The State failed to prove the broom handle, as used, was likely to produce great bodily harm.	The broom handle, used to strike the head and causing injury, qualifies as a dangerous weapon.	Sufficient evidence supported the jury's finding it was a dangerous weapon.
Can a defendant be convicted of both second-degree assault and domestic assault for the same act under Minn. Stat. § 609.04?	Domestic assault is a lesser degree of second-degree assault; thus, two convictions are barred.	Only offenses within the same ordinal statutory degree scheme (e.g., 1st-5th degree assault) count as lesser degrees.	Domestic assault is not a lesser degree of second-degree assault; convictions for both are permitted.

State v. Moss, 269 N.W.2d 732 (Minn. 1978) (ordinary objects can be dangerous weapons depending on manner of use)
State v. Born, 159 N.W.2d 283 (Minn. 1968) (jury determination appropriate for whether an object is a dangerous weapon)
State v. Upton, 306 N.W.2d 117 (Minn. 1981) (head strike with a similar object sufficient for assault with a dangerous weapon conviction)
State v. Hackler, 532 N.W.2d 559 (Minn. 1995) (included offenses determined by statutory degrees)
State v. Bookwalter, 541 N.W.2d 290 (Minn. 1995) (multiple offenses, single behavioral incident—sentencing for only one offense)