State v. Morgan, 824 N.W.2d 98

Casey Morgan, engaged to Mary Lindley, cared for Lindley’s daughter K.N. (6) and Lindley’s son D.M. (3) in their home.
On Jan. 26, 2011 Morgan purportedly disciplined K.N. for arguing and for not finishing homework after hearing a dispute with D.M.
Morgan grabbed and squeezed K.N.’s face with force, causing extensive bruising and facial injuries.
K.N. was taken to school, showed distress, and later described the squeezing incident; bruising prompted school officials to notify authorities.
Dr. John Hill examined K.N. and found injuries consistent with significant force; DSS initiated protective custody proceedings for K.N. and D.M.
Morgan was charged with aggravated child abuse, found guilty by a jury, and sentenced as a habitual offender with most of the term suspended.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of the evidence for aggravated child abuse	Morgan contends evidence is insufficient	State argues evidence supports guilt beyond reasonable doubt	Sufficient evidence supports guilt beyond a reasonable doubt
Applicability of the reasonable discipline defense	Morgan argues defense of reasonable force should apply	State contends injuries were not permissible discipline	Court did not address authorization on review; conviction affirmed on sufficiency

State v. Beck, 785 N.W.2d 288 (S.D. 2010) (sufficiency standard for challenging evidence on appeal)
State v. Carter, 771 N.W.2d 342 (S.D. 2009) (reasonable doubt standard; guidance on sufficiency review)
State v. Janklow, 693 N.W.2d 685 (S.D. 2005) (standard for reviewing conflicts in the evidence)
State v. Buchholz, 598 N.W.2d 899 (S.D. 1999) (sufficiency of circumstantial evidence and reasonable inferences)
In re C.F., 708 N.W.2d 313 (S.D. 2005) (permissible discipline and reasonable force; statutory defense)