State v. Villanueva-Gonzalez

¶1 Miguel Angel Villanueva-Gonzalez was convicted of second degree assault and fourth degree assault for attacking his girlfriend. He contends that his actions constituted one assault and therefore his two convictions violate double jeopardy. To analyze his claim, we look to how the legislature has defined “assault” and determine whether the legislature intended to punish assault as a course of conduct or upon each individual act. However, the legislature has not provided a definition of assault and the common law definition is ambiguous. Thus, we are guided by the many other jurisdictions…