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People v. Jennings

Supreme Court of California
237 P.3d 474 (2010)


Facts

The State of California (plaintiff) charged and tried together Martin Jennings (defendant) and his wife, Michelle Jennings, for the death of their son, Arthur Jennings. Witness testimony established that the Jennings regularly inflicted serious physical harm upon Arthur and refused to feed him, leaving him thin and undernourished. Immediately prior to Arthur’s death, Jennings struck Arthur in the head with a fireplace shovel. Arthur died within an hour of the attack. Forensic pathologist Dr. Frank Sheridan performed the autopsy on Arthur’s body and testified that Arthur was severely emaciated and malnourished; Sheridan also provided further testimony concerning the extensive physical injuries Arthur suffered over the years leading up to the assault. At the time of death, Arthur had three drugs in his system, including a dose of Unisom that would have been sufficient to cause death in a child of Arthur’s size and condition. When questioned at trial about the cause of Arthur’s death, Sheridan stated that a combination of the drugs, physical injuries, and malnutrition caused Arthur’s death. Sheridan further explained that given Arthur’s overall condition, his death likely would have been imminent, even absent the ingestion of drugs. A jury convicted Jennings. Jennings appealed, contending that there was insufficient evidence to establish that his physical abuse of Arthur was a but-for cause of Arthur’s death, rather than the ingestion of drugs.

Rule of Law

Issue

Holding and Reasoning (George, C.J.)

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