The Tennessee Supreme Court today reinstated a jury’s verdict finding a Davidson County woman, Shalonda Weems, guilty of aggravated child neglect. The Court concluded that the evidence at trial could have led a reasonable jury to determine that the State successfully proved all of the necessary elements for aggravated child neglect beyond a reasonable doubt.
On the morning of March 3, 2005, Ms. Weems found her six-month-old daughter barely breathing and turning blue in her crib. Her daughter was later pronounced dead at Vanderbilt Medical Center in Nashville. Approximately ten years later, Ms. Weems was charged with felony murder and aggravated child neglect related to her daughter’s death. At a jury trial, the evidence showed that an autopsy investigation concluded the daughter’s primary cause of death was severe dehydration and chronic malnutrition and the circumstance of her death was homicide. Testimony from the medical examiner revealed there was almost no food or waste in the daughter’s stomach or intestinal tract, among a number of other indicators of dehydration and malnutrition. Ms. Weems repeatedly made statements to investigators that she fed her daughter and denied withholding food or failing to take care of her daughter. The jury found Ms. Weems guilty of reckless homicide and aggravated child neglect.
Thereafter, Ms. Weems filed a motion for judgment of acquittal on both charges. The trial court denied the motion as to the reckless homicide charge but granted the motion as to the aggravated child neglect charge. The trial court reasoned that the evidence was insufficient to prove Ms. Weems acted knowingly, an essential element of the crime of aggravated child neglect. The State appealed arguing that the trial court improperly applied the standard of review when considering the motion by making conclusions that were solely the job of the jury and by failing to view the evidence in the light most favorable to the prosecution, among other errors.
The Court of Criminal Appeals affirmed the trial court’s decision to grant the motion as to the aggravated child neglect charge. The court explained that, based on the evidence presented at trial, it was unclear exactly what happened leading up to the child’s death. Ultimately, the court held that the evidence was insufficient to prove that Ms. Weems knowingly failed to feed the child or knowingly neglected the child. The Tennessee Supreme Court granted the State’s request for permission to appeal.
In its unanimous opinion, the Tennessee Supreme Court held that the trial court erred in applying the standard of review when considering a motion for judgment of acquittal. The Court reasoned that the trial court improperly weighed the evidence, an exclusive duty of the jury under the context of this type of motion, and failed to disregard countervailing evidence or recognize the jury’s ability to draw inferences and make conclusions from the evidence presented at trial. The Court reversed the decision of the Court of Criminal Appeals and vacated the trial court’s decision to grant the motion as to the aggravated child neglect charge. As a result, the Court reinstated Ms. Weems’ conviction for aggravated child neglect and remanded the case for further proceedings in the Criminal Court for Davidson County.
To read the Supreme Court’s opinion in State v. Shalonda Weems, authored by Chief Justice Jeff Bivins, visit the opinions section of TNCourts.gov.