Wilson v. United States, 24-CM-0736

C. Wilson was convicted of attempted second-degree cruelty to children after his seven-year-old son appeared at school with red marks on his upper left arm and said his dad did it. 1
Wilson defended on the ground that he used reasonable parental discipline after the child and his sister were caught stealing $40 from his dresser. 2
The trial evidence showed competing possibilities for the injury: a belt on C.W.'s bottom, a forceful grab of his arm, or a white plastic bat, and the trial court could not determine the cause. 3
The trial court nonetheless found the discipline unreasonable because the red marks showed excessive force, even though it could not say how they were inflicted. 4
On appeal, Wilson argued the government failed to disprove the reasonable parental discipline defense beyond a reasonable doubt. 5
The court reversed, holding the temporary marks and uncertain mechanism of injury did not prove unreasonable discipline under governing precedent. 6

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the government disproved reasonable parental discipline 7	Wilson says the evidence did not show unreasonable force beyond a reasonable doubt.	The government says the red marks alone showed excessive discipline.	The evidence was insufficient; conviction reversed. 8
Whether visible bruising or red marks alone defeat the defense 9	Wilson says temporary marks do not by themselves prove excessiveness.	The government says any bruising or marks exceed reasonable discipline.	No; marks alone do not obviate the defense. 10
Whether uncertainty about how the injury occurred matters 11	Wilson says the court could not infer an unreasonable mechanism from nonspecific marks.	The government says the photos and testimony support an inference of abuse.	No rational factfinder could determine the mechanism from the photos alone. 12

Johnson v. United States, 207 A.3d 606 (D.C. 2019) (sufficiency review and reasonable parental discipline burden framework 13)
Cave v. United States, 75 A.3d 145 (D.C. 2013) (at a bench trial, unresolved factual disputes count as reasonable doubt 14)
Lee v. United States, 831 A.2d 378 (D.C. 2003) (parental discipline is a complete defense if purpose is disciplinary and force is reasonable 15)
Florence v. United States, 906 A.2d 889 (D.C. 2006) (parental corporal punishment may be reasonable even when it leaves visible marks 16)
Longus v. United States, 935 A.2d 1108 (D.C. 2007) (risk of significant injury or pain can inform excessiveness analysis 17)
In re L.H., 925 A.2d 579 (D.C. 2007) (minor temporary marks and discoloration were insufficient to prove abuse in neglect context 18)
Powell v. United States, 916 A.2d 890 (D.C. 2006) (forceful arm grab during discipline did not prove excessive force beyond a reasonable doubt 19)
Ross v. United States, 331 A.3d 220 (D.C. 2025) (inferences and common sense cannot substitute for evidence 20)
W.H. v. D.W., 78 A.3d 327 (D.C. 2013) (parents have a fundamental right to control and direct their children 21)