## Facts

- William P. Ripley and his wife, Mary, had state placement of a 15-month-old child in their home and were seeking to adopt him.
- On May 30, 1995, the child was rushed to the hospital after being found not breathing and nonresponsive; he was pale, limp, and struggling to breathe.
- Medical testing showed severe brain trauma, including bleeding and swelling; a pediatric neurologist testified the pattern was acceleration-deceleration trauma consistent with shaken-baby syndrome.
- The neurologist explained that the injuries involved torn veins in the brain (“shear” injuries) and that such injuries require violent, rapid shaking—far more force than ordinary jostling, bouncing, or other everyday handling.
- The child suffered permanent impairments, including paralysis on the right side and cognitive limitations.
- Ripley initially told police the child’s injuries came from a fall. After an officer told him the injuries were consistent with violent shaking, Ripley admitted he had shaken the child.
- At trial, Ripley claimed the child began to fall in the shower and that Ripley grabbed him, causing the child’s head to snap back; on cross-examination Ripley again acknowledged shaking the child but denied being angry, denied shaking violently, and said he did not intend harm or know shaking could cause such harm.
- A witness testified that on the day of the incident Mary Ripley said she and William had put the child in the shower as punishment for misbehavior.
- The jury found Ripley guilty of aggravated battery of a child.
- At sentencing, eleven witnesses testified for Ripley, and Ripley apologized while maintaining he did not intend the outcome. The court considered mitigation but concluded probation would not match the seriousness of the conduct and imposed a 10-year prison sentence. The trial court denied Ripley’s motion to reconsider, and he appealed.

## Issues

1. Whether the evidence was sufficient to prove beyond a reasonable doubt that Ripley acted intentionally or knowingly in causing great bodily harm to the child.
2. Whether the trial court abused its discretion by imposing an excessive 10-year sentence, including by allegedly misweighing mitigation or improperly treating intent as an aggravating factor.

## Decision

- The appellate court affirmed Ripley’s conviction for aggravated battery of a child.
- The court held that the jury could infer the required mental state from circumstantial evidence, including the violent nature of the act shown by medical testimony, the severity and character of the injuries, Ripley’s inconsistent explanations, and the testimony suggesting the shower incident was punishment rather than an accident.
- The court rejected the view that the State had to prove Ripley’s subjective awareness that shaking could cause serious injury, concluding that medical and circumstantial proof may establish that injuries were inflicted intentionally or knowingly even when the defendant claims ignorance.
- The appellate court affirmed the 10-year sentence as within the statutory range and not an abuse of discretion.
- The court found no improper double counting of intent at sentencing; the judge’s comments were understood as addressing the seriousness and predictable consequences of intentionally shaking the child with violent force, not as adding an extra factor beyond the offense.

## Legal Principles

- Intent and knowledge are commonly proven through circumstantial evidence and reasonable inferences drawn from the surrounding facts.
- The nature and extent of a victim’s injuries may support an inference that the defendant acted intentionally or knowingly.
- In shaken-baby prosecutions, medical testimony describing the degree of force and injury mechanism may support a finding that the defendant knowingly or intentionally caused great bodily harm.
- A defendant’s claim that he did not know shaking could cause severe injury does not bar the trier of fact from inferring knowledge or intent from the objective circumstances and the violence required to produce the injuries.
- Appellate review of sentencing is deferential; a sentence within statutory limits will be upheld absent an abuse of discretion, and the court may weigh the seriousness of permanent harm to a very young victim against mitigating evidence.

## Conclusion

People v. Ripley affirmed both the aggravated battery conviction and the 10-year prison term where medical testimony established that the child’s catastrophic injuries could only be produced by violent shaking, allowing the jury to infer Ripley’s intent or knowledge despite his claim of accident and lack of awareness, and where the sentencing court acted within its discretion in concluding that probation would not reflect the gravity and lasting consequences of the offense.


People v. Ripley, 685 N.E.2d 362 (1997)