State v. Patterson
For manslaughter, the mental state of recklessness requires a subjective awareness of the risk of death, while criminal negligence is measured objectively and, therefore, despite the defendant's mental disability and finding that she was not guilty of manslaughter, sufficient evidence supported her conviction of criminally negligent homicide. The decision included the following facts. A two year old boy was placed in the care of Sharon Patterson. Her IQ of 61 placed her in the bottom one half of one percent of the population. She restricted the child's access to fluids to correct behavioral problems. For four days, the toddler had little or nothing to drink and consumed hot sauce set out to discourage him from drinking out of others people's cups. Patterson found him not breathing and called emergency personnel, reporting that the child was dehydrated. The child died from insufficient fluid intake. Because of Patterson's cognitive disabilities, it was found that she did not know that withholding liquids could cause the child to die. She did generally understand that depriving someone of fluids can cause dehydration. The trial court found Patterson not guilty of manslaughter in the first and second degrees, but convicted her of the lesser included offense of criminally negligent homicide with two counts each of risk of injury to a child and cruelty to persons. On appeal, the Appellate Court affirmed and reversed the judgment in part, rejecting the defendant's claim that because of her mental disability insufficient evidence supported her conviction of criminally negligent homicide, cruelty to persons and risk of injury under the "situation prong" of C.G.S. §53-21(a)(1). For criminally negligent homicide, the Appellate Court explained, the standard is objective, one of a reasonably prudent person and specific intent was not required for the risk of injury or cruelty to persons convictions. The Supreme Court granted the defendant's petition for certification to appeal and ruled that the Appellate Court properly determined that the state presented sufficient evidence that the defendant had the required mental state to convict her of the three crimes. The Supreme Court affirmed the Appellate Court's judgment and adopted its opinion as a proper statement of the issues and applicable law.