United States v. Woods

484 F.2d 127 (4th Cir. 1973)

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Nature of the Case

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Facts

Woods was charged with the care of Paul David Woods, an eight-month-old preadoptive son. From August 4, 1969, until his death on September 21, 1969, Paul was subject to a number of unexplained incidents of cyanosis and respiratory difficulties. The medical examiner stated in his report, that Paul's death was not suicide or accident and that there was a 75% certainty that his death was caused by smothering, but there was reasonable doubt. As part of its case in chief, the government went into Woods' prior history of custody of children and put into evidence that of the nine children she cared for they had 20 episodes of cyanosis with seven of the children dead. D was convicted and appealed contending that the government had not proved the corpus delicti beyond a reasonable doubt; that evidence of other unconvicted bad acts is not admissible to show the death of the alleged victim, and that the other crimes presented did not rise to the level of clear and convincing evidence.