Morehead v. United States

Summary

The court affirmed Morehead’s conviction for assaulting A.A., holding that transferred intent applies to a nonfatal assault when the defendant intentionally assaults one person, unintentionally injures another, and the unintended victim is actually injured. The court concluded that Morehead intended to pepper-spray Adams and that the evidence established A.A. was struck and injured, so no separate intent toward A.A. was required. The court did not decide whether recklessness independently satisfies the mens rea requirement for attempted-battery assault.