Reck v. Alabama
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In this case, the issue before the Supreme Court was whether sufficient evidence on the element of "serious bodily injury" for the purposes of a first-degree assault offense could be established by the testimony of a lay witness, or, as a matter of law, it could be presented only through medical testimony or the victim’s testimony. The appeals court held that a mother’s testimony concerning her child’s suffering "serious and protracted disfigurement" was not sufficient evidence of the serious-bodily-injury element of first-degree assault to present the question to the jury. Defendant Timothy Reck was intoxicated when he drove his vehicle into the vehicle of Donna Loving. Her sons were passengers in the vehicle. She explained that her son’s face sustained numerous little scars caused by shattered glass that nicked his face. Upon careful review of the trial court record, the Supreme Court found that "serious bodily injury" in the form of "serious and protracted disfigurement" could be established by the testimony of a lay witness. The Court reversed the appellate court’s holding and remanded the case for further proceedings.
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