State v. Fletcher

Summary

The Ohio Second District Court of Appeals affirmed Ashlee Fletcher’s conviction for involuntary manslaughter arising from the death of her 14-year-old son after complications from Type 1 diabetes. The court held that the evidence was legally sufficient and that the conviction was not against the manifest weight of the evidence, concluding that Fletcher acted recklessly by failing to obtain medical care despite repeated diabetes-management training and warnings. The court’s judgment followed an earlier reversal based on the trial court’s failure to instruct the jury on recklessness for the predicate child-endangering offense.

Holdings

1. The evidence was sufficient for a rational trier of fact to find beyond a reasonable doubt that Fletcher recklessly violated her duty of care to C.N., thereby creating a substantial risk to his health or safety, and that the violation proximately caused his death as the predicate felony for involuntary manslaughter.
2. The convictions were not against the manifest weight of the evidence because the jury did not clearly lose its way in resolving the evidence and witness-credibility disputes.
3. Sufficiency of the evidence is a question of law reviewed de novo, and the evidence must be viewed in the light most favorable to the prosecution.

Questions Presented

1. Whether the evidence was legally sufficient to support Fletcher's conviction for involuntary manslaughter based on felony endangering children.
2. Whether Fletcher's convictions were against the manifest weight of the evidence.

Disposition

affirmed