STEPHON BROWN v. UNITED STATES.
146 A.3d 110
| D.C. | 2016Background
- On December 15, 2014, Gregory Dowell was assaulted by two men while making a food delivery; his iPhone, wallet, vest, and bicycle were taken; he later was diagnosed with a concussion.
- Police used GPS-monitoring data to identify Stephon Brown as having been in the area at the time; Dowell’s bicycle was found in Brown’s backyard and Brown was arrested.
- At trial a jury convicted Brown of robbery and assault with significant bodily injury; Brown appealed arguing insufficient evidence both that he was the perpetrator and that the injury was “significant.”
- Key prosecution evidence: Dowell’s eyewitness identification, GPS tracking data placing Brown near the scene between ~8:50–8:55 p.m., and discovery of the customized bicycle at Brown’s residence.
- Medical evidence: photographs of head/face injuries; ambulance medics urged hospital evaluation; five days later Dr. Pheasant diagnosed a concussion after a CAT scan and gave activity-limitation instructions and follow-up.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of evidence that Brown was the assailant | Government: eyewitness ID, GPS data consistent with victim’s account, bicycle found in Brown’s backyard support conviction | Brown: GPS and timeline inconsistent; he claimed he found an abandoned bicycle and rode it home | Affirmed — evidence (ID, GPS within margin of error, unexplained possession of stolen bike) supported a reasonable juror’s finding beyond a reasonable doubt |
| Whether injury constituted “significant bodily injury” under D.C. Code § 22‑404(a)(2) | Government: repeated blows to the head, lingering symptoms, CAT scan, and physician’s concussion diagnosis/treatment plan show injury required immediate medical attention | Brown: Victim was not hospitalized and did not receive substantial treatment; argued injury not “significant” | Affirmed — concussion with testing and physician-directed care/monitoring met the statutory definition of significant bodily injury |
Key Cases Cited
- Nero v. United States, 73 A.3d 153 (D.C. 2013) (standard of de novo review for sufficiency claims)
- Blair v. United States, 114 A.3d 960 (D.C. 2015) (evidence of repeated blows to the head requiring testing can support significant bodily injury)
- White v. United States, 300 A.2d 716 (D.C. 1973) (sufficiently unexplained possession of recently stolen property supports an inference of guilt)
- In re R.S., 6 A.3d 854 (D.C. 2010) (definition and inquiry for "significant bodily injury" — hospitalization or immediate medical attention)
- Quintanilla v. United States, 62 A.3d 1261 (D.C. 2013) (focus on objective nature of injury and whether, in ordinary course of events, it would require immediate medical attention)