People v. Iniguez case brief

People v. Iniguez case brief summary
872 P.2d 1183 (1994)

CASE SYNOPSIS

State filed a petition for review of a judgment of the Court of Appeal (California), that reversed defendant's conviction for rape, that concluded the evidence was insufficient to show the act of sexual intercourse was accomplished by means of force or fear of immediate and unlawful bodily injury, and that reduced defendant's conviction to sexual battery.

CASE FACTS
State challenged a judgment of the lower court reversing defendant's conviction for rape, finding the evidence insufficient to show that sexual intercourse was accomplished by means of force or fear of immediate and unlawful bodily injury, and reducing the conviction to sexual battery.

DISCUSSION

• The court reversed the judgment of the lower court, holding that the jury could reasonably have concluded that under the totality of the circumstances, the victim genuinely and reasonably feared immediate and unlawful bodily injury, and that such fear allowed defendant to accomplish sexual intercourse with the victim against her will. 
• The court focused on a 1980 amendment to Cal. Penal Code § 261 to eliminate the requirement that a rape victim resist the attacker, noting that some victims respond by "freezing." 
• Substantial evidence proved the element of fear of immediate and unlawful bodily harm both subjectively and objectively because testimony of the victim and the investigating officer showed that the victim was fearful, and because the circumstances of the attack showed that her fear was reasonable.

CONCLUSION
The court reversed the judgment of the lower court and remanded the case for further proceedings, concluding that under the totality of the circumstances, the evidence was sufficient to support the rape conviction because there was substantial evidence that the victim genuinely feared immediate and unlawful bodily injury and there was substantial evidence that her fear was reasonable.


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