Nature of the Case
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Facts
D lived with her daughter and a boyfriend, Watts. Watts regularly beat the child and subjected her to various forms of sadistic abuse. D also struck the child on occasion, sometimes with a belt or strap. During a beating by Watts, the child fell and hit her head on a piece of furniture. D could not awaken her child the next morning. Watts called the police and fabricated a story to explain the child's injuries, which included a bloodied nose and bruised forehead. he stated cause of death was multiple injuries to the head and trunk. The lower court premised D's culpability on her failure to protect her child from the more regular and severe beatings inflicted by Watts. D was charged with involuntary manslaughter. 'A person is guilty of involuntary manslaughter when as a direct result of the doing of an unlawful act in a reckless or grossly negligent manner, or the doing of a lawful act in a reckless or grossly negligent manner, he causes the death of another person.' D was convicted of involuntary manslaughter and appealed.
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