State v. Calaycay
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The Supreme Court reversed the judgment of the intermediate court of appeals (ICA) reversing Defendant's conviction of harassment and affirmed the district court's judgment, holding that Defendant's harassment conviction was supported by substantial evidence.
Defendant was charged with harassment stemming from statements he made to a complaining witness (CW), a seventeen-year-old female. CW testified that Defendant made sexually explicit comments to her that made her feel uncomfortable, unsafe, and scared. CW, however, did not explicitly state that she believed Defendant intended to cause her bodily injury, an essential element of the offense charged. The district court determined that Defendant's statements caused CW to believe that Defendant intended to have non-consensual sexual contact with her. The ICA reversed, concluding that there was no evidence that CW reasonably believed Defendant intended to cause her bodily injury. The Supreme Court reversed, holding (1) both elements of harassment and the requisite state of mind were supported by evidence adduced at trial; and (2) Defendant's constitutional challenges were without merit.
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