## Facts

- Steven Russell Sedlock’s son, J.T., was a fourth-grade student who was having disciplinary problems at school and was sent to the assistant principal’s office.
- Sedlock met with the assistant principal and then checked J.T. out of school.
- As Sedlock and J.T. left the office area, the assistant principal saw Sedlock kick J.T. in the buttocks and knee him in the back.
- Concerned for J.T.’s safety, the assistant principal called police.
- Officers went to Sedlock’s home, observed multiple injuries on J.T., and arrested Sedlock.
- Paramedics examined J.T. at the residence.
- Evidence at trial included testimony about visible marks and bruises on J.T.’s body, including injuries consistent with being struck with a belt.
- Sedlock admitted that, after they got home, he spanked/whipped J.T. with a belt, but he claimed it was justified parental discipline and not intended to cause severe harm.
- The State charged Sedlock in separate bills with second degree battery and cruelty to juveniles.
- After the matters were tried together in a bench trial, the court found Sedlock guilty of simple battery (as a lesser responsive offense) on the battery charge and guilty as charged of cruelty to juveniles.
- Sedlock appealed only the cruelty-to-juveniles conviction and sentence.

## Issues

1. Whether the evidence was sufficient to prove cruelty to juveniles under La. R.S. 14:93, including that Sedlock’s conduct constituted “mistreatment” causing “unjustifiable pain or suffering,” rather than reasonable corporal punishment.
2. Whether the cruelty-to-juveniles sentence contained an error on the face of the record because the probation component following suspension of the jail term was indeterminate or not stated with sufficient certainty.

## Decision

- The court affirmed Sedlock’s conviction for cruelty to juveniles.
- Applying the Jackson v. Virginia sufficiency standard, the court held that a rational factfinder could conclude beyond a reasonable doubt that Sedlock’s actions went beyond reasonable discipline and caused unjustifiable pain and suffering.
- The court relied on the physical evidence of multiple injuries and the trial court’s acceptance of the State’s witnesses over Sedlock’s characterization of the events.
- On error-patent review, the court found the probationary portion of the cruelty-to-juveniles sentence was not stated in a determinate, legally correct manner.
- The court remanded for resentencing limited to correcting the probation term/conditions while otherwise leaving the conviction and basic sentence structure intact.

## Legal Principles

- La. R.S. 14:93 prohibits the intentional or criminally negligent mistreatment or neglect of a child under 17 when unjustifiable pain or suffering results.
- “Mistreatment” is understood in its ordinary sense and is treated as abuse; the statute targets conduct that causes unjustifiable pain or suffering, not every instance of corporal punishment.
- A parent may use corporal punishment, but the factfinder may treat punishment as criminal mistreatment when the force used and the resulting injuries show the discipline exceeded what was reasonably necessary.
- Evidence is sufficient if, when viewed in the light most favorable to the prosecution, any rational trier of fact could find each element proven beyond a reasonable doubt.
- Appellate courts generally defer to the factfinder’s credibility choices when the record supports them.
- Louisiana appellate courts review the record for errors patent; a sentence must be determinate, and when a jail term is suspended in favor of probation, the probation term and conditions must be stated with clarity and legal accuracy.

## Conclusion

The Third Circuit upheld Sedlock’s cruelty-to-juveniles conviction because the evidence of kicking, kneeing, and belt-whipping—together with the child’s multiple injuries—supported a finding of mistreatment causing unjustifiable pain and suffering, but it remanded for resentencing to fix an indeterminate probation component.


State v. Sedlock, 882 So.2d 1278 (2004)