People v. Ford

Defendant, then age 19, was convicted of 2 counts of aggravated battery and 2 counts of battery, sentenced to 3 years on first aggravated battery charge but not sentenced on remaining charges. Victim, age 15, gave consent for Defendant to place him in a choke hold in exchange for cigarettes. While in choke hold, victim gave signal for Defendant to release him, but Defendant did not, and victim lost consciousness, had a seizure, and awoke with a nosebleed. Consent is not a valid defense to aggravated battery. Evidence was sufficient to reasonably conclude without need for expert medical testimony that Defendant’s choke hold caused victim’s nosebleed. Factfinder could reasonably infer that Defendant knowingly caused victim to lose consciousness, which is a form of bodily harm. (McDADE and LYTTON, concurring.)