State v. Galusha

The State appeals the dismissal of an attempted extortion charge against defendant Harold Galusha. It argues that “injury to the person” in 13 V.S.A. § 1701 includes injury other than physical harm and that the trial court should not have dismissed the charge for lack of a prima facie case. V.R.Cr.R 12(d). We agree and reverse.

The State’s information alleged that defendant delivered a letter to a female minor, in which he threatened to disclose a sexually explicit videotape to the minor’s parents and custodian unless she agreed to continue their relationship. The videotape showed defendant…