AI Generated Opinion Summaries

Decision Information

Decision Content

This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.

Facts

  • In May 2018, the Defendant, Timothy Trejo-Vigil, subjected his girlfriend to a series of beatings over two days using various objects, resulting in severe injuries and the miscarriage of their unborn child. The attacks occurred in their shared bedroom, where the Defendant also restricted the Victim's movements and forced her to urinate in a bottle. The Defendant's violent spree ended when he allowed the Victim to seek medical help, which led to police involvement and the subsequent investigation revealing the Defendant as the assailant (paras 2-3).

Procedural History

  • [Not applicable or not found]

Parties' Submissions

  • Appellant (Defendant): Argued that the convictions for attempted murder and five counts of aggravated battery with a deadly weapon against a household member violated the prohibition against double jeopardy because they were based on unitary conduct. The Defendant contended that the State did not differentiate the acts underpinning the attempted murder charge from those constituting the aggravated battery charges, leading to an overlap that infringed upon double jeopardy protections (para 5).
  • Appellee (State): [Not applicable or not found]

Legal Issues

  • Whether the Defendant's convictions for attempted murder and five counts of aggravated battery with a deadly weapon against a household member were based on unitary conduct, thus violating the prohibition against double jeopardy (para 5).

Disposition

  • The Court reversed the Defendant’s convictions for aggravated battery with a deadly weapon against a household member, upholding the conviction for attempted murder (para 11).

Reasons

  • Judges Jacqueline R. Medina, J. Miles Hanisee, and Shammara H. Henderson concurred in the opinion. The Court found that the Defendant's conduct, which led to both the attempted murder and aggravated battery charges, was unitary, meaning the same conduct was used to justify multiple charges. This finding was based on the State's reliance on identical evidence to prove both the attempted murder and aggravated battery charges, without distinguishing between the acts or Defendant's intent for each charge. The Court applied the two-part test from Swafford v. State, determining that the Legislature did not intend to authorize multiple punishments for the same conduct under the statutes in question. Consequently, to avoid a double jeopardy violation, the Court vacated the convictions carrying the shorter sentences, which were the five counts of aggravated battery with a deadly weapon against a household member, while upholding the more severe charge of attempted murder (paras 6-11).
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