COA finds sufficient evidence to affirm trial conviction for violating domestic abuse injunction by sending Facebook message.
State v. Clinton J. Adams, 2025AP1179, 11/26/25, District II (ineligible for publication); case activity
COA affirms jury’s conviction for knowingly violating a domestic abuse injunction over sufficiency challenge.
At trial, “Hailey” testified that she and Clinton Adams were in a relationship for eleven years until Hailey obtained an order of protection against Adams from the Manitowoc County Circuit Court in 2019, which is effective until 2029. The order prohibits Adams from any contact with Hailey and causing any person other than one of their attorneys or a law enforcement officer to contact Hailey unless she consents in writing. (¶ 2). “Contact” is defined to include “contact . . . by electronic communication or device.” (¶ 2).
Hailey said she and her daughter were on vacation in 2020 when her daughter received a Facebook message from “Clinton John Adams” stating “I need to speak with your mom asap.” (¶ 3). Hailey did not consent to Adams contacting her daughter and reported the incident to police while providing a screenshot of the message. (¶ 3).
Hailey’s daughter testified that she was on vacation with her mother when she received the Facebook message, took a screenshot of it, and sent it to her mother. (¶ 4). A police officer testified that he was familiar with Facebook, knows that a user has to log in to access it, knows that Facebook accounts are protected by a password, knows that Facebook accounts are associated with individual emails, and knows that Facebook profiles and messages list the given names on those profiles. (¶ 6).
Adams did not dispute on appeal that he knew there was an injunction and that one of the terms of the injunction prohibited him from contacting Hailey through a third party. He argued, however, there was insufficient evidence to support the jury finding that he committed the act of sending the Facebook message to Hailey’s daughter. (¶ 12).
The Court rejected Adams’ argument because the jury heard testimony from Hailey that she saw the screenshot of a Facebook message from “Clinton John Adams” stating “I need to talk to your mom asap.” (¶ 13). The jury also heard Hailey’s daughter confirm that she received the Facebook message, took a screenshot of it, and sent it to her mother. And the jury heard from the officer regarding how Facebook accounts work to prevent unauthorized access. “From these facts, a jury could reasonably conclude that Adams sent the Facebook message to Hailey’s daughter in an attempt to contact Hailey.” (¶ 13).
Although the officer testified that he did not contact Facebook to confirm the message’s authenticity, the Court noted that Adams did not testify and did not offer any contrary evidence to consider “as an alternative to the reasonable inference that the Facebook message sent by ‘Clinton John Adams’ to Hailey’s daughter requesting to speak to her mother originated from Adams.” (¶ 14).