Willful Infliction of Corporal Injury Case in California

In People v. Jackson (2000) 77 Cal.App.4th 574, the defendant was convicted of "willfully inflicting" corporal injury on his girlfriend in violation of section 273.5. The defendant had pushed his girlfriend against a car during an argument as the girlfriend tried to get away from him; she turned around, tripped over the curb, and fell, suffering abrasions to her leg. Based on the legislative history of the statute, Jackson concluded that the offense was intended to apply when "the corporal injury results from a direct application of force on the victim by the defendant." ( Jackson, supra, at p. 580.) Since the victim was injured when she tripped, rather than as a result of force applied directly by the defendant, the court found insufficient evidence to support the section 273.5 conviction.