State v. Hobbs, 301 Kan. 203

Hobbs punched Nienke outside a bar, causing a life-threatening basilar skull fracture that nearly killed him.
Hobbs was convicted of aggravated battery under K.S.A. 2011 Supp. 21-5413(b)(1)(A).
The district court gave a jury instruction treating aggravated battery as a general intent crime requiring only a intentional act, not the exact resulting harm.
Hobbs appealed, arguing the statute requires knowing both the conduct and the resulting harm; the Court of Appeals agreed with the State’s broader view.
The Kansas Supreme Court granted review to decide whether the State must prove that Hobbs knew that great bodily harm or disfigurement would result.
The Court held that ‘knowingly’ in 21-5413(b)(1)(A) means the defendant acted while knowing that great bodily harm or disfigurement was reasonably certain to result, and that the evidence was sufficient to convict.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the State proved Hobbs acted knowingly that great bodily harm was certain to result	State only needed to prove the underlying act was intentional	Hobbs argues knowing the result is required	Yes; knowledge of the result is required to some extent; sufficient evidence supported conviction

State v. Coman, 294 Kan. 84, 273 P.3d 701 (2012) (parens materia harmony; statutory construction guidance)
State v. Diaz & Altemay, 232 Kan. 307, 654 P.2d 425 (1982) (aggravated battery as involving intent to injure)
State v. Frierson, 298 Kan. 1005, 319 P.3d 515 (2014) (statutory harmonization; unit of prosecution considerations)
State v. Coman, 294 Kan. 84, 273 P.3d 701 (2012) (see above)