State of West Virginia v. Charles Gary Adams, Jr., 16-1038

On January 27, 2016, Charles Gary Adams Jr. assaulted Steven Wickline at The Station convenience store; the attack was captured on store video and resulted in visible facial and eye injuries.
Adams was indicted on malicious assault, destruction of property, and second-offense domestic assault (the domestic-assault charge involved his ex-girlfriend, not Wickline).
Adams moved pretrial for a change of venue, claiming publicity from multiple indictments and his reputation in the small Monroe County community would prevent a fair trial; the motion was denied.
At trial the State presented video of the beating, eyewitness testimony, photographs of injuries, and medical testimony documenting severe abrasions, swelling, and a vitreous hemorrhage; the jury convicted on all counts.
Adams filed a post-verdict motion for judgment of acquittal arguing insufficient evidence of intent required for malicious assault; the trial court denied the motion and sentenced him.
The Supreme Court of Appeals of West Virginia affirmed, finding no abuse of discretion on venue and sufficient evidence of intent for malicious assault.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether trial court abused discretion in denying change of venue	State: defendant failed to show good cause or actual prejudice; venue decision is discretionary	Adams: publicity from multiple indictments and local reputation in small county made a fair trial impossible	Denial affirmed — Adams offered no evidence (e.g., clippings, juror bias) proving prejudice so severe to warrant transfer (no abuse of discretion)
Whether evidence was insufficient for malicious assault (intent to maim, disfigure, disable, or kill)	State: video, eyewitnesses, photos, and medical records supported intent element	Adams: he lost control and lacked requisite intent; did not intend to seriously harm Wickline	Denial of acquittal affirmed — viewing evidence in State’s favor a rational jury could find requisite intent beyond a reasonable doubt

State v. Wooldridge, 129 W.Va. 448, 40 S.E.2d 899 (1946) (standard for change of venue; defendant bears burden to show good cause)
State v. Gangwer, 169 W.Va. 177, 286 S.E.2d 389 (1982) (publicity alone does not require change of venue absent extreme prejudice)
State v. Juntilla, 227 W.Va. 492, 711 S.E.2d 562 (2011) (de novo review for denial of judgment of acquittal on sufficiency grounds)
State v. Guthrie, 194 W.Va. 657, 461 S.E.2d 163 (1995) (appellate standard for reviewing sufficiency: view evidence in light most favorable to prosecution)
State v. Hughes, 225 W.Va. 218, 691 S.E.2d 813 (2010) (issues not raised below generally not considered on appeal)