U.S. v. Stands Alone

Record contained sufficient evidence to support defendant-prisoner’s conviction for inflicting bodily injury to federal officer in violation of 18 USC section 111, arising out of incident in which defendant discharged fire extinguisher on prison guard after failing to adhere to guard’s directives in encounter within prison, where guard experienced visual impairment and physical pain from chemical burns from exposure to fire suppressant and pepper spray. Section 111(a) penalizes individuals who “forcibly assaults, resists, opposes, impedes, intimidates or interferes with any” correctional officer, and instant incident fell within contours of section 111(a). Ct. rejected defendant’s argument that: (1) assault must be essential element in all offenses under section 111; and (2) because his indictment did not charge him with assault, he could only be convicted of different offense under 18 USC section 3559(a)(9). Ct. further noted that defendant’s argument would lead to absurd result, where individual could use force to resist, impede, intimidate or interfere with federal official, and yet escape stated reach of section 111(a) so long as said conduct did not constitute assault.