DC misdemeanor conviction reversed for trial court’s failure to explain ruling

In Ben Saidi v. United States, the DC Court of Appeals considered the defendant’s appeal of his conviction for criminal assault.  At trial, the defendant argued he had not assaulted anyone, but instead used lawful force to remove a trespasser from his apartment, which is a recognized defense under DC law.

Although the Court specifically held that the government presented enough evidence to defeat this defense, the Court still reversed the conviction.  Why?  Because, in the Court’s view, the trial court had not explained in enough detail why it convicted the defendant.

This case illustrates the power of Superior Court Criminal rule 23 (and the comparable Federal rule) to appeal bench trial convictions.  Unlike a jury trial, where the verdict is simply “guilty” or “not guilty”, the trial court must explain in detail its findings of facts and law.  Any mistake or omission could result in reversal, as it did for Mr. Ben Saidi.


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