State v. Belleville

Chad Belleville (defendant) admitted he was checking a text message when he drove across a median turning lane into oncoming traffic and struck another car, seriously injuring the child inside. At the scene, Belleville initially denied texting or calling before the crash and, when his phone showed no recent call history, told police he had "erased the history or something." Eight months later, Belleville admitted he had looked down to check a text and never saw the oncoming cars before impact; phone records confirmed calls and texts shortly before the crash. Belleville was convicted of second-degree assault, which required proof he "recklessly" caused serious bodily injury, and he appealed, arguing the evidence of recklessness was insufficient.