Hobbs v. Nevada

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Justia Opinion Summary

Patricia McClain was at a nail salon having her nails done when Defendant Timothy Hobbs entered and became belligerent. After an argument between the two, Defendant left the salon, only to return later. He spit in Ms. McClain’s face, and threw a rock through her vehicle’s windshield. The State charged Defendant with domestic battery, injury to property and requested a “habitual criminal” sentence enhancement. Ultimately the district court convicted Defendant and sentenced him to 10 to 25 years in prison for domestic battery with an additional year for property damage. Defendant appealed, challenging whether spitting on another constituted battery under state law. Furthermore, Defendant challenged whether the evidence introduced against him at trial was sufficient to support the enhanced sentence. The Supreme Court ruled that spitting does constitute battery under state law, and that the evidence presented at trial was sufficient to support his conviction and the sentence he received. The Court affirmed the district court’s decision.

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