## Facts

- Ronald S. Jackson became a co-owner of a Washington, D.C. house when his wife added his name to the deed.
- In January 1998, the couple separated; Jackson moved out while Mrs. Jackson continued living in the house.
- On June 13, 1998, Jackson called Mrs. Jackson seeking to retrieve sunglasses from the house; she told him he could not come at that time.
- Jackson nevertheless went to the house; when Mrs. Jackson saw him, she went inside and locked the door.
- Jackson forced entry through the locked front door, damaging it.
- Mrs. Jackson testified that, after entering, Jackson threatened to burn the house down.
- Jackson was acquitted by a jury of threats to do bodily harm but, in a bench trial, was convicted of malicious destruction of property for damaging the front door under D.C. Code § 22-303.

## Issues

1. Whether a co-owner can be convicted of malicious destruction of property under D.C. Code § 22-303, which applies to property “not his or her own.”
2. If so, whether the evidence was sufficient to prove beyond a reasonable doubt that Jackson maliciously destroyed the front door.

## Decision

- The court affirmed the conviction.
- It held that a co-owner may be held criminally liable under § 22-303 for maliciously destroying jointly owned property.
- It concluded the evidence permitted a rational factfinder to find that Jackson intentionally and maliciously damaged the front door, harming his wife’s property interest.

## Legal Principles

- Statutory interpretation is reviewed de novo.
- Under D.C. Code § 22-303, the phrase “not his or her own” does not bar prosecution merely because the defendant holds a partial ownership interest.
- A co-owner may be convicted for malicious destruction when the defendant’s intentional, malicious damage injures another co-owner’s property interest in jointly held property.
- Evidence is sufficient if, viewing it in the light most favorable to the government, a rational trier of fact could find guilt beyond a reasonable doubt.

## Conclusion

The court held that co-ownership is not a defense to malicious destruction of property where the defendant’s intentional, malicious act damages jointly owned property and thereby harms another owner’s property interest, and it affirmed Jackson’s conviction based on sufficient evidence of forced entry that damaged the co-owned front door.


Jackson v. United States, 819 A.2d 963 (D.C. 2003)