Sagner v. State
Florida District Court of Appeal
791 So.2d 1156 (2001)
Relevant factsFree
Maurice Sagner (defendant) intentionally threw a bottle at a man, which would have been simple battery had it hit him, but instead the bottle unintentionally struck a bystander, permanently damaging her eye. The State charged Sagner with aggravated battery, defined as battery causing permanent disability, and the jury was instructed on transferred intent -- that intent to harm one person can transfer to an unintended victim actually harmed; Sagner was convicted and appealed.
IssueFree
Whether the transferred-intent doctrine is applicable if a difference in status between the intended victim and the unintended victim would enhance the severity of the offense.