Young v. the State
332 Ga. App. 361
Ga. Ct. App.2015Background
- Defendant Brandon Ray Young was tried by jury and convicted of aggravated battery and aggravated assault on a correctional officer after an incident in the Henry County jail on May 27, 2010.
- While being fingerprinted and handcuffed, Young struck a correctional officer in the head as she leaned over to retrieve gloves; a video of the incident was shown to the jury.
- The officer collapsed, lost consciousness, and testified she blacked out and later found herself on the floor.
- Prosecution charged aggravated battery (OCGA § 16-5-24) and aggravated assault (OCGA § 16-5-21) on a correctional officer, invoking enhanced penalties for attacks on officers performing official duties.
- Young argued the evidence was insufficient to show he rendered the officer’s head “useless” (aggravated battery) and that he ‘‘knowingly’’ committed the assault, pointing to evidence of mental instability.
- The jury found Young guilty; on appeal the court reviewed sufficiency under Jackson v. Virginia and affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency for aggravated battery on a correctional officer | State: video and testimony show Young struck officer causing loss of consciousness, rendering head "useless" | Young: no evidence he rendered the officer’s head useless even temporarily | Affirmed — jury could find loss of consciousness rendered the head temporarily useless, supporting aggravated battery conviction |
| Sufficiency for aggravated assault on a correctional officer | State: striking officer in head with fists (while handcuffed) is use of an object likely to cause serious injury; officer was in uniform performing duties | Young: challenges mens rea — did not ‘‘knowingly’’ assault due to mental instability | Affirmed — jury could find fists/handcuffed hands were used offensively likely to cause serious injury; officer’s uniform and conduct supported knowledge she was an officer |
| Knowledge defendant assaulted an officer in official capacity | State: officer in uniform and acting in official duties, known employee of jail | Young: claimed mental instability might negate knowledge or intent | Affirmed — evidence supported that Young knew victim was a correctional officer performing duties |
| Mental-capacity/insanity defense sufficiency | Young: presented evidence of irrational and impulsive behavior and mental-health diagnoses to challenge culpability | State: mental evaluations showed no evidence of delusions, inability to distinguish right from wrong, or delusional compulsion at time of offense | Affirmed — mental abnormality short of insanity is not a defense; evaluations permitted jury to reject insanity/capacity defense |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (1979) (standard for appellate review of sufficiency of the evidence)
- Miller v. State, 273 Ga. 831 (2001) (conviction upheld where some competent evidence supports each element)
- Walls v. State, 283 Ga. App. 560 (2007) (temporary reduced use of a bodily member can satisfy aggravated battery)
- Scott v. State, 243 Ga. App. 383 (2000) (blows causing memory lapses and nerve damage supported aggravated battery)
- Hewitt v. State, 277 Ga. 327 (2003) (whether hands/fists are objects likely to cause serious injury is a jury question)
- Gamble v. State, 235 Ga. App. 777 (1998) (handcuffed defendant striking victim with hands/fists/handcuffs sufficient for aggravated assault)
- Chandler v. State, 204 Ga. App. 816 (1992) (uniform and conduct can show defendant knew victim was an officer)
- Thomas v. State, 320 Ga. App. 101 (2013) (mental abnormality short of insanity is not a defense)
- Cline v. State, 199 Ga. App. 532 (1991) (discussing criminal intent required for aggravated assault)