State of Tennessee v. David Harold Hanson

Summary

The Tennessee Supreme Court reversed the Court of Criminal Appeals and reinstated the defendant's aggravated child abuse conviction, holding that the circumstantial medical and custodial evidence permitted a rational jury to find beyond a reasonable doubt that he knowingly, other than by accidental means, inflicted six leg fractures on the two-month-old victim, and that the resulting extreme physical pain constituted serious bodily injury. Applying Ducker's classification of aggravated child abuse as a nature-of-conduct offense, the court held that the 'knowing' element reached only awareness of the nature of the treatment, not awareness that the conduct was 'abusive' or of the resulting injury. The court also upheld the trial court's acquittal-first jury instructions as constitutionally permissible under State v. Davis and sustained its rejection of the defendant's special requests for supplemental definitions of 'knowing conduct' and 'accidental means.'