Hawaii Supreme Court
911 P.2d 725 (1996)
Minor, a 14-year-old special education student who was prone to lie, was required to bring home to her mother and her mother’s boyfriend, Delbert Crouser (defendant), a daily progress report from school. One day, Minor forgot to pick up the report from her counselor for her teachers to sign and, instead, filled out the report herself, changed some of the grades and attendance record. Crouser learned that Minor had changed the report and went to her room to punish her. Crouser spanked Minor numerous times on her bare buttocks with his hand as well as with a plastic baseball bat. The following day, Minor had difficulty sitting down in class due to the bruises that had formed on her buttocks. The school health aide and counselor observed the bruising and also noticed bruising to Minor’s arm, thigh, and torso. When questioned by school officials, as well as the police, Crouser admitted to spanking Minor but claimed that he did not feel that he had gone beyond reasonable discipline. Crouser was indicted for abuse of a family and household member. At trial, many people testified to the seriousness of the bruising on Minor’s body. One individual said in her experience she had never seen such extensive bruising in a parental discipline case and considered Crouser’s actions excessive. Minor’s mother testified that she observed the entire discipline event and did not believe that Crouser acted excessively and would have intervened if she felt Minor was seriously harmed. Crouser was convicted and he appealed.
Rule of Law
Holding and Reasoning (Moon, C.J.)
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