State v. Crouser
Hawaii Supreme Court
911 P.2d 725 (1996)
A 14-year-old special-education student (Minor), who lived with her mother and the mother's boyfriend, Delbert Crouser (defendant), forged her own school progress report after forgetting to have it signed. When Crouser discovered this, he spanked her repeatedly on her bare buttocks with his hand and a plastic baseball bat, leaving bruising so severe that school staff noticed it the next day along with bruises on her arm, thigh, and torso, and Minor could not sit comfortably for weeks. Crouser admitted spanking her but insisted it was reasonable discipline; Minor's mother, who watched the whole incident, agreed it was not excessive, but school witnesses and medical testimony described the bruising as unusually extensive. Crouser was convicted of abuse of a family or household member and appealed.
Whether a defendant's use of force to discipline a minor in his care is justified only if it is used with due regard to the minor's age and size and is reasonably related to safeguarding or promoting the minor's welfare.