The Superior Court held that Pennsylvania’s Sentencing Commission could apply the domestic-violence enhancement even when no minor witnessed the assault.
The Third Department affirmed denial of DVSJA resentencing where the defendant’s claimed childhood abuse occurred in 2002–2003 but the murder was committed in 2007 — finding insufficient temporal nexus and that his own testimony undermined the causation element.
The North Carolina Court of Appeals affirmed a Domestic Violence Protective Order entered against a father who grabbed his seven-year-old son by the neck and hip and carried him to his car seat, causing the child to feel dizzy, experience difficulty breathing, and turn red in the face. A 2–1 majority held that competent evidence supported the finding of “intentionally causing bodily injury” under N.C. Gen. Stat. § 50B-1(a)(1) even absent a visible mark. The court also held that minor children have standing to seek DVPOs against parents through a Guardian ad litem. Judge Wood dissented, arguing that routine parental discipline without lasting injury cannot constitute domestic violence.
The Wyoming Supreme Court summarily affirmed a divorce decree granting Mother sole custody of ten children and assigning nearly all marital debt to incarcerated Father, holding that Father’s nine-issue opening brief contained no cogent argument — just general legal principles with no case-specific analysis — and that his reply brief improperly raised four new issues while failing to respond to Mother’s arguments. Attorney fees under W.R.A.P. 10.05 were declined as a matter of discretion, but costs were awarded.
The Utah Court of Appeals affirmed Aaron Verive’s four class B misdemeanor convictions for unlawful detention and domestic violence in the presence of a child, holding that momentarily blocking a preferred exit—whether a doorway or a vehicle—satisfies the unlawful detention statute regardless of duration or alternative routes, and that events immediately following the charged acts were intrinsic evidence outside Rule 404(b)’s other-acts exclusion.