People v. Phillips

175 Cal. Rptr. 703 (1981)

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People v. Phillips

California Court of Appeal
175 Cal. Rptr. 703 (1981)

  • Written by Tammy Boggs, JD

Facts

Priscilla Phillips (defendant) was married, mother to two sons, highly educated, employed, kind, and caring. After learning that she could no longer bear children, Phillips and her husband adopted a Korean infant named Tia. Not long after the adoption, Tia became ill. Over the course of the next year, Tia endured numerous medical tests and treatments. Phillips always accompanied Tia, who would seem to improve but then would suffer recurring bouts of vomiting and diarrhea. Doctors had no explanation. Tests during several hospital visits showed Tia had elevated levels of sodium. In February 1977, Tia died with an extreme level of sodium in her blood. Several months later, Phillips adopted another Korean infant girl named Mindy. Mindy and Tia were not biologically related. On the one-year anniversary of Tia’s death, Mindy was admitted to the hospital for vomiting and diarrhea with elevated sodium in her blood. Doctors began to consider the possibility that Mindy was being poisoned, and hospital staff closely watched Mindy’s intake of formula. The hospital tested a bottle of formula made by Phillips, and the results showed an inordinately high sodium level. Phillips was forbidden from feeding Mindy, who quickly recovered thereafter. The state (plaintiff) charged Phillips with murdering Tia and endangering the life of Mindy. Trial evidence included expert testimony from Dr. Martin Blinder regarding a condition known as Munchausen syndrome by proxy. Blinder testified generally about the condition, in which certain people, usually outwardly caring mothers, made their own young children sick to garner sympathy and attention. Blinder testified that he had not met or examined Phillips. In response to a “hypothetical question” as to whether Phillips’s repeated, secretive administration of sodium to Tia and Mindy was consistent with Munchausen’s syndrome, Blinder responded affirmatively as to a “hypothetical person.” The jury convicted Phillips of the charged crimes. Phillips appealed, arguing that the expert testimony was improperly admitted.

Rule of Law

Issue

Holding and Reasoning (Grodin, J.)

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