18 N.Y.3d 160 (2011)
To be convicted of second-degree assault for attacking an EMT under New York Penal Law § 120.05(3), the assailant must have intended to prevent the EMT from performing a lawful duty, not merely intended to cause injury.
Summary
Christian Bueno was convicted of second-degree assault for attacking an EMT, William Spinelli, as Spinelli was entering his ambulance after responding to a call. The New York Court of Appeals affirmed the conviction, holding that there was sufficient evidence for the jury to infer that Bueno intended to prevent Spinelli from performing a lawful duty as an EMT, even though Spinelli had completed treating a patient at the scene. The dissent argued that the prosecution failed to prove Bueno had the specific intent to prevent Spinelli from performing a lawful duty.
Facts
EMTs Spinelli and Aanonsen responded to a call for medical assistance at 190 Butler Street in Brooklyn. Upon arrival, they treated a woman with a hand injury, who declined further treatment. As the EMTs were returning to their ambulance, Bueno, standing nearby, began screaming and threw a beer can at Spinelli. As Spinelli attempted to enter the ambulance, Bueno attacked him, knocking him to the ground and repeatedly punching him. Spinelli sustained injuries, including a deviated septum. Bueno claimed he was the person with the bleeding face who the EMT’s had failed to treat.
Procedural History
Bueno was charged with two counts of second-degree assault (one for Spinelli and one for Aanonsen) and two counts of third-degree assault. He was convicted of second-degree assault against Spinelli, and acquitted of all charges related to Aanonsen. The Appellate Division affirmed the conviction. The New York Court of Appeals granted leave to appeal and affirmed the Appellate Division’s decision.
Issue(s)
Whether the evidence presented at trial was legally sufficient to establish that Bueno acted with the intent to prevent an EMT from performing a lawful duty when he caused physical injury to the EMT, as required for a conviction of second-degree assault under New York Penal Law § 120.05(3).
Holding
Yes, because there was sufficient evidence for the jury to infer that Bueno intended to prevent Spinelli from performing a lawful duty as an EMT. The EMT was in uniform and about to enter his ambulance after completing one call, and the jury could reasonably conclude that he was still performing his duties, whether he was on his way to another call or returning to the hospital.
Court’s Reasoning
The Court reasoned that Penal Law § 120.05(3) is intended to protect public servants, like EMTs, who are exposed to a heightened risk of violence while performing their duties. The Court rejected Bueno’s argument that the EMTs’ response was “finished” once they left the apartment, finding it reasonable for the jury to conclude that Spinelli was performing his job duties when he attempted to leave the premises, regardless of whether he was headed to another call or back to the hospital. The Court emphasized that a jury is entitled to infer that a defendant intended the natural and probable consequences of his acts and that intent is rarely proven by an explicit expression. Quoting People v Barnes, 50 NY2d 375, 381 (1980), the court stated: “[c]ompeting inferences to be drawn [regarding the defendant’s intent], if not unreasonable, are within the exclusive domain of the finders of fact, not to be disturbed by us.” The dissent argued that the prosecution failed to prove Bueno had the specific intent to prevent Spinelli from performing a lawful duty, and that the viciousness of the assault did not rationally lead to the conclusion that Bueno had the requisite intent to interfere with Spinelli’s lawful duties. The dissent stated “the People established only that the victim was subjected to an entirely unexplained, senseless assault at the hands of defendant, and that is precisely why the evidence was insufficient to sustain the conviction under Penal Law § 120.05 (3).”