Quimbee logo
DMCA.com Protection Status
From our private database of 18,800+ case briefs...

Noakes v. Virginia

Supreme Court of Virginia
699 S.E.2d 284 (2010)


Elizabeth Noakes (defendant) ran a day-care service from her home. For three weeks, Noakes had been watching Noah Colassaco, a 15-month-old child who had difficulty getting to sleep. While other children slept, Noah stood in the crib and cried. One day, Noakes put Noah in the crib for a nap in an upstairs-loft bedroom. Noah had been standing and crying for about a half hour when Noakes devised a plan: if Noakes could get Noah into a sitting or lying position, Noah would fall asleep. Noakes placed a cardboard cover on the crib to prevent Noah from standing upright. Noakes next placed a dog crate weighing over 33 pounds on top of the cardboard. Noakes shook the crib a few times to see if the cover was stable. Satisfied that the cover was secure, Noakes left the loft at 1:00 p.m. Three hours later, Noakes returned to the loft and found Noah unconscious in the crib. Noah was standing, with his head and neck wedged between the cover and the crib. Noakes and emergency-medical personnel could not revive Noah. After a bench trial, the court convicted Noakes of involuntary manslaughter. The court found that Noakes had acted recklessly and indifferently. The court of appeals affirmed, upholding the trial court’s conclusion as reasonable and noting that Noakes could have foreseen the danger in placing a heavy dog crate across the crib of a baby who often stood and cried. Noakes appealed to the Supreme Court of Virginia, claiming that Noakes did not act with criminal negligence and could not have foreseen the actions taken by Noah in the crib.

Rule of Law


Holding and Reasoning (Kinser, J.)

What to do next…

  1. Unlock this case brief with a free (no-commitment) trial membership of Quimbee.

    You’ll be in good company: Quimbee is one of the most widely used and trusted sites for law students, serving more than 499,000 law students since 2011. Some law schools—such as Yale, Vanderbilt, Berkeley, and the University of Illinois—even subscribe directly to Quimbee for all their law students. Read our student testimonials.

  2. Learn more about Quimbee’s unique (and proven) approach to achieving great grades at law school.

    Quimbee is a company hell-bent on one thing: helping you get an “A” in every course you take in law school, so you can graduate at the top of your class and get a high-paying law job. We’re not just a study aid for law students; we’re the study aid for law students. Read more about Quimbee.

Here's why 499,000 law students have relied on our case briefs:

  • Written by law professors and practitioners, not other law students. 18,800 briefs, keyed to 985 casebooks. Top-notch customer support.
  • The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
  • Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
  • Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.

Questions & Answers

Have a question about this case?

Sign up for a free 7-day trial and ask it

Sign up for a FREE 7-day trial