Legal Opinion

Handy v. State

District Court of Appeal of Florida

Decided September 28, 1994No. 94-0029Published

1Per curiam

Appellant challenges his sentence alleging several errors in the calculation of his scoresheet. Although errors were committed, we find that the recalculation will not change his sentence. We specifically reject his challenge to the victim injury points added to his sentence for slight injury, as the victim received a headache from the blow inflicted by appellant which lasted a significant period of time. We conclude that this constitutes physical trauma. Nowhere do the rules or statutes require such trauma to be externally visible. Cf. Audano v. State, 641 So.2d 1356, 1361 (Fla. 2d DCA 1994).

2Cases cited2 opinions

  1. Audano v. StateDistrict Court of Appeal of Florida · 1994
  2. Crawford v. StateDistrict Court of Appeal of Florida · 1993

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