State v. Trombley
Supreme Court of Vermont
807 A.2d 400 (2002)
Matthew Trombley (defendant) repeatedly punched George Demarais outside a bar, knocking out some of his teeth, and Vermont (plaintiff) charged him with aggravated assault; at trial, Trombley claimed he seriously injured Demarais only in self-defense against Demarais's knife attack. The trial court instructed the jury it could find Trombley acted either purposely or knowingly in striking Demarais, and the jury convicted him; Trombley appealed, arguing that since he was charged with purposely causing harm, the trial court erred by instructing the jury that knowingly causing harm would also satisfy the mens rea for aggravated assault.
Whether a person can be criminally liable for aggravated assault if the person's primary, conscious objective was to inflict serious bodily injury on another.