State v. Graham

A release agreement is sufficient evidence to prove knowledge of all trial and required court appearances. Also, when a defendant files a motion for judgment of acquittal due to insufficient evidence he must state the specific theory on which the proof is insufficient.

Defendant appealed his two contempt of court convictions based on the trial court's error. Defendant was charged with a wildlife violation and given a release agreement at his arraignment. Defendant failed to appear in court on his following court date, which violated the terms of his release agreement. The agreement stated that Defendant agrees "to appear at all trial and required court appearances." Defendant did appear at Court on a later date, but failed to appear again for a rescheduled hearing. The Court of Appeals held that the release agreement provided sufficient evidence of notice to Defendant that he was obligated to appear at all court proceedings. Further, on Count Two, Defendant did not preserve his objection because his motion did not state a specific theory on which the State's proof was insufficient. The Court held that Defendant was reasonably aware of obligated court appearances. Affirmed.