The Superior Court held that Pennsylvania’s Sentencing Commission could apply the domestic-violence enhancement even when no minor witnessed the assault.
The Third Department affirmed denial of DVSJA resentencing where the defendant’s claimed childhood abuse occurred in 2002–2003 but the murder was committed in 2007 — finding insufficient temporal nexus and that his own testimony undermined the causation element.
The Utah Court of Appeals affirmed Aaron Verive’s four class B misdemeanor convictions for unlawful detention and domestic violence in the presence of a child, holding that momentarily blocking a preferred exit—whether a doorway or a vehicle—satisfies the unlawful detention statute regardless of duration or alternative routes, and that events immediately following the charged acts were intrinsic evidence outside Rule 404(b)’s other-acts exclusion.