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State v. Small

Louisiana Supreme Court
100 So. 3d 797 (2012)


At approximately 10 p.m. on January 20, 2008, Satonia Small (defendant) went to her friend’s home to drink, leaving her two young children, J.D. and S.S., unsupervised in Small’s apartment. About an hour later, Small was alerted that a fire had started in the building. When Small returned home, she learned that S.S. had been found unconscious inside the apartment. Days later, S.S. died of smoke inhalation and carbon monoxide poisoning as a result of the fire. The State of Louisiana (plaintiff) charged Small with second-degree murder based on an underlying felony charge of cruelty to juveniles. Fire investigators later determined a pan that had melted on the stove in Small’s apartment caused the fire. At trial, testimony was presented regarding Small’s prior guilty plea to criminal abandonment arising from a 2007 incident in which Small left her children unattended. At the time of the plea, Small promised not to leave her children unsupervised again. A jury convicted Small of second-degree murder, and Small appealed, contending that the fire directly caused her daughter’s death, rather than Small’s lack of supervision.

Rule of Law


Holding and Reasoning (Victory, J.)

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