Wilson v. United States

Summary

The District of Columbia Court of Appeals reversed C. Wilson's conviction for attempted second-degree cruelty to children, holding the evidence insufficient to disprove his reasonable-parental-discipline defense beyond a reasonable doubt. Because Wilson's disciplinary purpose was undisputed, the government bore the burden of proving the force unreasonable; yet the trial court made no finding as to how the child's temporary red marks were inflicted, and there was no evidence of swelling, persistence beyond the morning, or medical treatment beyond ice from the school nurse. The court corrected the legal error committed below—that any force hard enough to leave marks defeats the defense—reaffirming that short-lived red marks or bruises, standing alone and without regard to causation, do not supply even an inference that corporal punishment exceeded the wide bounds D.C. precedent allows.