Sunday, November 17, 2013

State v. Crouser case brief

State v. Crouser case brief summary
911 P.2d 725 (1996)

Defendant appealed his conviction from the District Family Court of the Third Circuit (Hawaii) for abuse of a family and household member in violation of Haw. Rev. Stat. § 709-906 (1993). Defendant alleged that his use of force was justified pursuant to Haw. Rev. Stat. § 703-309(1).

Defendant was convicted of physically abusing his girlfriend's daughter who lived in his home. Defendant disciplined the child by striking her bare buttocks, arm, thighs and torso, with a plastic bat. The child suffered severe bruising and she was unable to sit in her classes due to the injuries.


  • On appeal, the court affirmed the conviction. 
  • The court held that: 
  • (1) the trial court's finding that the force used by defendant was not reasonably related to the purpose of safeguarding the child's welfare was not clearly erroneous; 
  • (2) the trial court's finding that beating was designed to cause or known to create substantial bodily injury, extreme pain, or mental distress was not clearly erroneous; and 
  • (3) Haw. Rev. Stat. 703-309(1) was not vague not overbroad because it described, with sufficient clarity, the level of force that could justifiably be used in the discipline of a minor.

The court affirmed the trial court's judgment that convicted defendant.

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