Williamson v. State, 113 A.3d 155

Williamson was charged with Assault Second Degree on a law enforcement officer after an initial offense of offensive touching; bench trial in March 2014 resulted in a conviction and a four-year sentence with supervisory terms.
Williamson argued the evidence did not prove physical injury to the officer, contending only offensive touching was shown.
Facts show Williamson challenged Abram in a DOJ conference room, threw a transcript, punched and wrestled with Abram, and was restrained with assistance from another officer.
Abram sustained a bruise on the back of his leg and a pulled groin, with four to six weeks of limited movement; he did not seek medical treatment.
Williamson did not request a judgment of acquittal at trial and did not raise sufficiency issues in a post-trial motion, raising questions about the proper standard of review on appeal.
The court ultimately held that Abram's injuries satisfied the statutory standard for physical injury to a police officer, supporting the Assault Second Degree conviction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Standard of review for sufficiency after bench trial without acquittal motion	Williamson argues for plain error review.	State advocates treating as sufficiency review similar to motion for acquittal.	Sufficiency reviewed under rational trier of fact standard; treated as if a judgment of acquittal had been timely sought.
Whether evidence showed physical injury under 11 Del. C. § 612(a)(3) for a law-enforcement assault	Abram's injuries did not amount to physical injury.	Abram's bruising and functional impairment constitute physical injury.	Abram's injuries meet impairment of physical condition and thus satisfy physical injury.
Whether medical treatment is required to prove physical injury	Treatment was not required for physical injury.	No requirement for medical treatment to prove physical injury.	Medical treatment not required; testimony about impairment suffices.

McKnight v. State, 753 A.2d 436 (Del. 2000) (sufficiency of evidence for physical injury; bruising as evidence)
Harris v. State, 965 A.2d 691 (Del. 2009) (de minimis injuries not constituting physical injury)
Binaird v. State, 967 A.2d 1256 (Del. 2009) (abrasion and pain as sufficient physical injury evidence)