Stefon Diggs: NFL Receiver’s Acquittal and the Limits of “Not Guilty”

By Deandra Grant & Griffin Grant

Welcome to The Defense File where we examine the criminal cases of public figures through the lens of Texas criminal law. Each entry looks at what happened in court, what the defense argued, and what a defendant would have faced (and how they might have been defended) if the same facts had occurred in Texas.

The Incident

Stefon Diggs is a four-time Pro Bowl wide receiver who finished the 2025 season as the New England Patriots’ leading target before being released in March 2026. The allegations at trial centered on a single date: December 2, 2025, at his home in Dedham, Massachusetts.

The accuser, Jamila “Mila” Adams, had worked since July 2025 as Diggs’s live-in personal chef. She was paid by Diggs and lived in his home during the football season. According to her testimony, the two had previously had a romantic or sexual relationship before she was hired, but the relationship at the time of the alleged incident was not romantic. She described the dynamic on the stand as “complicated.”

Adams testified that on December 2, an argument escalated when Diggs entered her bedroom in the home, that he “smacked” her with an open hand, and that he then placed his arm around her neck and choked her. She did not report the incident to police on December 2. She did not report it on December 3, when she traveled to New York and stayed with a friend. She did not report it during the week she remained in New York. She reported it to the Dedham Police Department on December 16, 2025 which was fourteen days after the alleged event.

Diggs was charged later that month with one count of felony strangulation or suffocation under Massachusetts law and one count of misdemeanor assault and battery. He pleaded not guilty in February 2026.

The Trial and the Acquittal

The trial in Norfolk County District Court (Dedham) lasted two days. Judge Jeanmarie Carroll presided. Assistant District Attorney Drew Virtue prosecuted. The defense was led by attorneys Andrew Kettlewell, Mitchell Schuster, and Sara Silva.

The prosecution’s case rested on two witnesses:

Adams herself, who testified to the alleged assault.
Dedham Police Officer Kenneth Ellis, who took her December 16 report. On cross, Officer Ellis acknowledged he did not observe visible injuries on Adams when she came to the station, did not photograph any injuries, did not collect medical documentation, did not interview other witnesses before filing charges, and was unable to reach Diggs by voicemail before charges were filed.

That was the entirety of the State’s evidence. No medical records. No photographs of any injury. No 911 call. No witness who saw a mark, bruise, or change in behavior in the 14 days between December 2 and December 16.

The defense called seven witnesses.

A hairstylist, Xia Charles, testified that Adams stayed at her New York apartment in the days after the alleged incident. Charles testified she saw no bruising, no marks on Adams’s neck or face, no difficulty swallowing, and that Adams never mentioned any assault during their week together.
Members of Diggs’s household and professional staff (his chief of staff, his massage therapist, a nurse who had provided IV treatments, and others) testified that they saw Adams in the days after December 2 and observed no injuries and no behavioral changes.
Defense counsel introduced text messages between Adams and Diggs after December 2, including a December 13 message in which Adams asked for money and discussed a non-disclosure agreement but no mention of an assault.
Defense counsel also brought out, on cross-examination of Adams, that her own attorney had at some point made a $5.5 million civil settlement demand to Diggs.

In closing, defense attorney Andrew Kettlewell argued the State had not produced “a single shred of credible evidence” that an assault occurred. Diggs did not testify (his Fifth Amendment right). The case went to the jury after closing arguments that lasted just over half an hour.

The jury deliberated for roughly 90 minutes. On May 5, 2026, it returned a verdict of not guilty on both counts.

The Texas Analysis

In Texas, the same facts would have been charged under the assault statute in Texas Penal Code §22.01 if the State could prove a qualifying family, household, or dating relationship between Diggs and Adams. Without that relationship, the same conduct is a Class A misdemeanor assault (not a felony) unless the State could meet the higher proof requirements of aggravated assault under §22.02. The dating-relationship element is not an enhancement bolted onto an already-felony charge. It is the gatekeeper that determines whether the conduct is a felony at all.

Strangulation: Texas Penal Code §22.01(b)(2)(B)

Texas Penal Code §22.01(a)(1) defines basic assault (intentionally, knowingly, or recklessly causing bodily injury to another) as a Class A misdemeanor (up to one year in county jail; fine up to $4,000).

22.01(b) then lists circumstances under which the offense becomes a third-degree felony (2–10 years in TDCJ; fine up to $10,000). The strangulation language sits inside one of those circumstances. Read with the structure restored, §22.01(b)(2) provides:

“[T]he offense is a felony of the third degree if the offense is committed against … (2) a person whose relationship to or association with the defendant is described by Section 71.0021(b), 71.003, or 71.005, Family Code, if:

(A) [a prior family-violence-related conviction is shown on the trial of the offense]; or

(B) the offense is committed by intentionally, knowingly, or recklessly impeding the normal breathing or circulation of the blood of the person by applying pressure to the person’s throat or neck or by blocking the person’s nose or mouth.”

The statutory structure matters. The relationship requirement in the parent clause governs both subparagraphs. (A) and (B) are two alternative additional facts that, when paired with a qualifying relationship under Family Code §71.0021(b), §71.003, or §71.005, lift the offense from a Class A misdemeanor to a third-degree felony. The “or” sits between (A) and (B). It does not sit between the relationship element and the strangulation element.

Essentially, If the alleged victim is a family member, then choking is a Third Degree Felony. If the alleged victim is not an intimate partner or family or household member, then the charge may only be a Class A Misdemeanor. That is the practical reality of charging under §22.01(b)(2)(B).

The Family Violence Affirmative Finding

If the dating-relationship element were established and a conviction obtained, the family-violence affirmative finding under Texas Family Code §71.004 would attach to the judgment. The consequences are permanent and significant:

Federal firearms prohibition under 18 U.S.C. §922(g)(9) (the Lautenberg Amendment) for any misdemeanor crime of domestic violence — permanent, with no law-enforcement or military exception.
Enhancement of any future assault on a family-violence relationship from Class A misdemeanor to third-degree felony.
Bar to expunction or non-disclosure.
Use in any subsequent civil family-court proceeding (custody, divorce, protective order).

What “Not Guilty” Doesn’t End: Civil, NFL, and Reputational Exposure

This is the part of the Diggs case that does not get explained well in headline coverage, and it is the most important part for any client who watches an acquittal on television and assumes the matter is over.

A criminal acquittal means one thing only: the State did not prove its case beyond a reasonable doubt to the unanimous satisfaction of a jury. “Beyond a reasonable doubt” is the highest standard of proof in American law. It is reserved for criminal cases because the State is asking permission to take a person’s liberty. It is not the standard that applies anywhere else.

The civil case: preponderance of the evidence

Adams’s civil claim survives the acquittal. A civil battery or assault claim, or a claim for intentional infliction of emotional distress, requires only preponderance of the evidence — “more likely than not,” or roughly 51%. The same testimony the jury found insufficient to support a criminal conviction can be enough to support a civil judgment, because the question is different. The question is no longer did the State prove this beyond reasonable doubt but rather is it more likely than not that this happened.

Adams’s attorney already made a $5.5 million civil settlement demand before the trial began. That number is now the floor of any civil negotiation, not the ceiling. And the discovery available in civil litigation (depositions, document requests, interrogatories) is far broader than what the defense or prosecution had access to in two days of trial. The clearest historical precedent is People v. Simpson (criminal acquittal, 1995) followed by Rufo v. Simpson (civil verdict for $33.5 million, 1997). Same defendant, same conduct, same evidentiary universe, opposite results, because the standards of proof are different.

The NFL personal conduct policy: the lowest standard of all

The NFL released a statement after the verdict confirming that Diggs’s case “remains under review of the Personal Conduct Policy.” That review is not bound by the verdict, by the Federal Rules of Evidence, or by the Fifth Amendment.

Standard of proof. The Personal Conduct Policy uses a “credible evidence” standard internally, which is below preponderance and far below reasonable doubt.
No Fifth Amendment. Diggs did not testify at his criminal trial. The Fifth Amendment privilege against self-incrimination does not apply to a private league’s investigation. If the NFL asks him to sit for an interview, refusal can itself be treated as a violation.
No subpoena power either way. The league cannot compel Adams to participate, but if she chooses to, the league can interview her, weigh her account, and reach its own conclusion regardless of the jury’s.
History matters. The NFL has suspended players under the Personal Conduct Policy who were never charged criminally (Ben Roethlisberger, Jameis Winston) or who were not indicted (Deshaun Watson, 11 games in 2022). An acquittal does not foreclose discipline.

As of the date of this post, Diggs is a free agent. Any new contract is likely to be conditioned, formally or informally, on the league’s clearance under the Personal Conduct Policy.

Reputation, endorsements, and morals clauses

Most major endorsement contracts include morals clauses giving the sponsor an option to terminate when an athlete becomes the source of legal or reputational controversy. Those clauses are typically not triggered by a verdict; they are triggered by the controversy itself, and they typically remain in place even after acquittal. A criminal verdict does not unwind a sponsor’s decision to walk away.

What Texas Lawyers and Texas Defendants Need to Take From This

Several practical points apply directly to Texas assault and family-violence cases:

“Dating relationship” is litigated, not assumed. Whether two people had a relationship that qualifies under Family Code §71.0021(b) is a fact issue. In Texas, an early defense workup should pin down the timing, nature, and continuity of any prior intimate contact. The difference between a Class A misdemeanor and a third-degree felony often turns on this single element.
Delayed reporting is admissible and it cuts both ways. Texas law admits delayed outcry, and prosecutors regularly explain it through experts on trauma and the dynamics of family violence. Defense counsel can also probe delay for what it shows about contemporaneous behavior. A 14-day gap with no medical documentation, no photographs, and no contemporaneous outcry to anyone in regular contact with the accuser is significant evidence the jury can weigh.
Strangulation cases without medical documentation are vulnerable. Strangulation can leave subtle injuries (petechiae, hyoid bone fractures, internal swelling) that require medical examination to document. When no exam was sought, no photographs were taken, and no third party observed marks, the State’s case rests on testimony alone. Texas juries can and do convict on testimony alone but they need to find the testimony credible beyond a reasonable doubt.
Civil exposure is part of the criminal defense conversation. In Texas, Code of Criminal Procedure Article 38.22 governs custodial statements; the broader question of whether a client should give a recorded statement to anyone (police, an HR investigator, an insurance carrier, a league, a sports agent) needs to be decided strategically with full awareness that anything said outside court can be used in parallel civil or administrative proceedings, even if the criminal case ends in acquittal.
Employer or licensing review runs on its own track. Whether a Texas client is a teacher, a nurse, a peace officer, a CDL driver, a contractor with a state license, or an NFL receiver, the employer or licensing body uses its own standard of proof and is not bound by what happens in criminal court. “Not guilty” does not equal “reinstated.”

How Would the Defense Approach This in Texas?

Several lines, run in parallel from intake forward:

Aggressive early discovery on the relationship. Text messages, social media, contractual documents (the chef agreement, any NDA), and prior contact patterns should be subpoenaed and preserved at the earliest possible moment to develop the full picture of the relationship under Family Code §71.0021(b).
Medical and physical evidence audit. Was a SANE exam offered? A photograph taken? Was Adams seen by any medical provider in the 14 days between the alleged event and the report? CCP Art. 39.14 (Michael Morton Act) demand should specifically request all medical and forensic records and the absence of records.
Civil-case and employer interplay. From the first call, defense counsel needs to know whether a civil demand has been made, whether NDAs are in play, whether HR or a regulator has been notified, and whether settlement discussions are running parallel to the prosecution. Plea negotiations cannot be evaluated in isolation.
Witness preparation, not coaching. In a case where staff and household members may be subpoenaed (as occurred in Dedham), every witness should be prepared on the rules of testimony, the prosecution’s likely cross, and the line between recollection and assumption. The Diggs defense putting up seven defense witnesses in a single afternoon is unusual; in Texas, the same volume can be handled but only with rigorous preparation.

What This Case Illustrates

The Diggs verdict is not a referendum on whether anything happened in that home on December 2, 2025. The jury did not say the alleged conduct didn’t occur. The jury said the State did not prove it beyond a reasonable doubt. Those are different findings, and the difference matters.

In a single-witness case with no medical documentation, no photographs, a 14-day reporting delay, contemporaneous text messages that did not reference an assault, multiple defense witnesses who saw the accuser in the relevant window without observing injuries, and a $5.5 million civil demand pending, a Texas jury would likely have asked the same questions a Massachusetts jury asked. The answers might still be different in the parallel processes that follow. Civil court is open. The NFL’s investigation is open. Reputation, in the modern media environment, is rarely closed by any verdict.

The lesson for clients (and for the lawyers who represent them) is that a criminal acquittal is the most important possible result and almost never the only result. Anyone who walks out of a criminal courtroom assuming the file is closed is mistaken about how parallel adjudication works in 2026.

Sources

The Defense File is an educational series. All Texas analysis is hypothetical and does not constitute legal advice about any specific case.

If you are facing assault, family-violence, or strangulation charges in Texas, call (214) 225-7117 for a free, confidential co

(972) 347-8833

(214) 225-7117

Assault & Family Violence, High Profile Arrests, The Defense Files