Sieniarecki v. State of Florida

Patricia Sieniarecki lived with her husband, her adult daughter Theresa Sieniarecki (defendant), her two adult sons, and Theresa’s boyfriend. After Patricia’s husband died and she had a second hip surgery, Patricia became despondent and disoriented, refusing to walk, even to the bathroom, and eating and drinking very little. A foreclosure action forced the Sieniareckis to sell the family home, and they moved into two apartments. It was agreed that Patricia would live in an apartment with Theresa and her boyfriend because Theresa did not work and could care for Patricia. Theresa changed Patricia’s diapers, helped her bathe, and prepared her meals. The brothers did not help. Theresa never sought advice, assistance, or medical care for Patricia. One morning, Theresa discovered Patricia dead in her bed. A detective found Patricia disheveled, smeared with feces, and laying on a mattress covered in feces and urine. Patricia’s autopsy revealed that she had no teeth, an empty stomach, and an infected foot ulcer, and was dehydrated. She also had sores from prolonged exposure to urine and feces. Theresa was convicted of neglect of a disabled adult under Florida law. She appealed, arguing that Florida’s neglect statute was unconstitutional because (1) it lacked a specific-intent requirement and therefore violated due process and (2) it was unconstitutionally vague. The state appeals court disagreed, affirming Theresa’s conviction. She appealed to the Florida Supreme Court.