Background
The Garland County Circuit Court adjudicated MC, then fifteen years old, delinquent for third-degree domestic battering after an altercation with her aunt, Brianna Neighbors. Brianna testified that she tripped over clothing, later slipped and struck a bookshelf, and suffered bruising on her face. She said MC came at her but did not put her hands on her, though she suggested any contact may have been a minor slap that left no mark.
A responding sheriff’s deputy observed red marks on Brianna’s face, a bump on her head, and hair coming out when Brianna ran her fingers through it. The deputy concluded MC should be arrested and believed Brianna’s injuries resulted from the incident. The circuit court found the deputy more credible than Brianna, denied MC’s dismissal motion, and entered the delinquency adjudication.
The Court’s Holding
The Arkansas Court of Appeals reversed and dismissed. Although the evidence substantially established that Brianna had physical injuries—visible marks associated with physical trauma—the State did not present evidence that MC caused them.
Neither Brianna, the deputy, nor MC’s grandmother testified that MC committed an act that caused Brianna’s facial or head injuries. Because proof that the victim was injured did not establish that MC inflicted those injuries, the evidence was insufficient to support third-degree domestic battering.
Key Takeaways
- A juvenile delinquency adjudication is reviewed under the same sufficiency standard as a criminal conviction.
- Third-degree domestic battering requires proof that the accused caused physical injury to a family or household member.
- Evidence of injuries alone cannot sustain an adjudication without evidence linking the accused’s conduct to those injuries.
Why It Matters
The decision underscores that a fact-finder may resolve credibility disputes, but the State still must offer substantial evidence on every element of the charged offense. Where the record establishes injury but not causation by the juvenile, reversal and dismissal is required.