State v. Bailey
Annotate this CaseThe State indicted Petitioner on kidnapping and assault in the second degree. A jury found Petitioner guilty of kidnapping and of the lesser included offense of assault in the third degree. Petitioner filed a motion for judgment of acquittal, arguing (1) the State failed to prove venue was proper in this case; and (2) the Class A felony kidnapping should be reduced to Class B kidnapping because the complainant did not sustain serious or substantial injury as shown by the jury acquitting Petitioner of assault in the second degree. The trial court denied the motion. The Supreme Court affirmed the convictions, holding (1) because several witnesses testified that the offense occurred on the island of Oahu, there was sufficient evidence to demonstrate the first judicial circuit was the correct venue; and (2) while the State must prove beyond a reasonable doubt that substantial bodily injury was caused by Defendant in order to disprove the mitigating defense that reduces the offense of kidnapping from a Class A felony to a Class B felony, the State disproved one of the three elements of the Class B mitigating defense beyond a reasonable doubt to establish that Defendant was not entitled to the defense.
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