State v. Crawford

406 S.E.2d 579 (1991)

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State v. Crawford

North Carolina Supreme Court
406 S.E.2d 579 (1991)

Facts

In May 1988, the extraordinary discipline methods of Angela West’s boyfriend, Jonathan Crawford (defendant), came to the attention of the Department of Social Services (the agency) of North Carolina (plaintiff). Angela had three children. Jonathan would discipline the children by hitting the bottom of their feet to hide bruises and putting hot sauce and soap in their mouths to prevent lying or cursing. Jonathan also used methods designed to publicly humiliate the kids. For example, Jonathan once punished six-year-old Christopher by making him wear a sign around his neck and making him read aloud the indiscretion written on the sign. Jonathan also made Christopher wear a diaper outside and carry a bottle for being a sissy. When the agency visited Angela’s home and learned from Jonathan about his discipline methods, the agency contacted the police. Jonathan was arrested for misdemeanor child abuse in June. Unfortunately, the charges were later dismissed, and after a no-contact order expired in August, Jonathan moved into the apartment with Angela and the children in September. On October 1, Jonathan spanked Christopher and his sibling Shaun twice and made them stand in the corner when the children took biscuits from the kitchen without permission. Christopher had a mild rash on his face. In the morning, Shaun reported that Christopher had vomited twice during the night Also, Christopher’s rash seemed worse. Although Angela wanted to take Christopher to the hospital, Jonathan convinced her not to, fearing child-abuse accusations and the children being removed. Jonathan claims that he thought Christopher had food poisoning and the best course was to flush his system. Jonathan then forced Christopher to drink multiple quarts of water over two to three hours and did not stop even as Christopher vomited dozens of times. Finally, Christopher screamed, began convulsing, and fell to the floor blind. Though an ambulance was called, Jonathan drove Christopher himself and reportedly stopped the vehicle for several minutes along the way. Christopher suffered brain death and was removed from a respirator the next day. Christopher’s autopsy showed fresh bruises on his thigh, buttocks, and head. Jonathan was charged with first-degree murder by torture and with deliberateness and premeditation. Jonathan was convicted and sentenced to life in prison. Jonathan appealed, arguing that his acts were accidental and warranted a charge of involuntary manslaughter, not murder, and that the torture statute was vague.

Rule of Law

Issue

Holding and Reasoning (Meyer, J.)

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