People v. Williams

Summary

The California Supreme Court clarified the mental state required for assault under Penal Code section 240. The court held that assault is a general-intent crime requiring an intentional act and actual knowledge of facts establishing that the act would probably and directly result in the application of physical force, but not a specific intent to injure or subjective awareness of the risk. The court found any ambiguity in the jury instruction harmless beyond a reasonable doubt and reversed the Court of Appeal's judgment.

Holdings

1. Assault is a general-intent crime that requires an intentional act and actual knowledge of the facts sufficient to establish that the act, by its nature, will probably and directly result in the application of physical force against another person.
2. Assault does not require a specific intent to injure the victim or a subjective awareness of the risk that injury will occur.
3. The former CALJIC No. 9.00 instruction was potentially ambiguous because its objective natural-and-probable-consequences language could permit conviction based on facts the defendant should have known but did not actually know.
4. Any ambiguity in the assault instruction was harmless beyond a reasonable doubt.

Questions Presented

1. What mental state is required to commit assault under California Penal Code section 240?
2. Does assault require a specific intent to injure or a subjective awareness of the risk that injury will occur?
3. Did the former CALJIC No. 9.00 assault instruction omit or misstate the required knowledge element?
4. Was any instructional error harmless beyond a reasonable doubt under the facts of the case?

Disposition

reversed_and_remanded