The People of the State of New York, Respondent v. James Chiddick, Appellant

Summary

The Court of Appeals held that the evidence was legally sufficient to support the jury's finding that the defendant caused 'substantial pain,' and therefore 'physical injury,' when he bit the victim's finger while trying to escape a burglary confrontation. The court explained that substantial pain means more than slight or trivial pain but need not be severe or intense, and identified relevant considerations: the objective injury, the victim's subjective description of pain, the pursuit of medical treatment, and the offender's motive. Applying these factors — a cracked fingernail and bleeding, testimony of 'moderate' pain, a hospital visit, and a motive to inflict maximum pain to break free — the court affirmed the Appellate Division order sustaining the second-degree burglary and assault convictions.