Darrell Daniels v. State of Indiana (mem. dec.)
49A02-1703-CR-522
| Ind. Ct. App. | Sep 14, 2017Background
- On May 4, 2013, paramedics found 15-month-old A.S.-D. unresponsive and cold; autopsy showed multiple blunt-force injuries (head, torso, abdomen) and internal hemorrhaging; death occurred 6–8 hours before discovery.
- Darrell Daniels lived in the home with girlfriend Nikita Dunn and Dunn's children; Daniels had cared for Dunn's children at times (cooked, bathed, changed diapers) and was the last caregiver before the child was found.
- Autopsy and medical testimony (Dr. Brewer-Paul, Dr. Harris) showed some external injuries were days old, internal bleeding had occurred for 3–4 days, and many symptoms (vomiting, seizures, decreased activity/appetite, thirst) would have been observable and that timely medical care likely would have saved the child.
- Daniels initially attributed bruises to accidental falls and sibling hairbrush strikes but later acknowledged only he and Dunn had been alone with the child in the prior weeks and suggested Dunn must have been the abuser.
- The State charged Daniels with Class A felony neglect of a dependent (Ind. Code § 35-46-1-4) because the neglect allegedly resulted in the child’s death; following a bench trial, Daniels was convicted.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Daniels voluntarily assumed care of the child | State: Daniels regularly cared for the child (cooking, changing, watching) and rented the home—he voluntarily assumed care | Daniels: He was not the parent/guardian and there was a delineation of responsibilities with Dunn; he lacked legal obligation | Court: Evidence supported that Daniels voluntarily assumed care (consistent with Dowler) |
| Whether Daniels knowingly placed the child in a situation endangering life/health | State: Visible, repeated bruising and symptoms would have made Daniels subjectively aware of a high probability the child was in danger; he either abused or was complicit | Daniels: He did not knowingly place child in danger and lacked authority to separate child from mother | Court: Circumstantial evidence supported knowing endangerment (either perpetrated or complicit), conviction affirmed |
| Whether Daniels knew the child required medical attention | State: External injuries and likely visible symptoms made the need for care actual and appreciable and subjectively known to Daniels | Daniels: He had no authority to take child to doctor and therefore could not be required to call 911; failure to report is a separate offense | Court: Evidence supported that Daniels was subjectively aware of the need for medical care and failed to act; conviction affirmed |
Key Cases Cited
- Dowler v. State, 547 N.E.2d 1069 (Ind. 1989) (voluntary assumption of care can be shown by regular caregiving even without legal obligation)
- Springer v. State, 585 N.E.2d 27 (Ind. Ct. App. 1992) (whether a child is a dependent is a question of fact)
- Fisher v. State, 548 N.E.2d 1177 (Ind. Ct. App. 1990) (distinguishes mere failure to report abuse from placing dependent in dangerous situation where defendant lacked authority to separate child)
- Gross v. State, 817 N.E.2d 306 (Ind. Ct. App. 2004) (definition of "knowingly" in endangerment context: subjective awareness of high probability of danger)
- Mitchell v. State, 726 N.E.2d 1228 (Ind. 2000) (when symptoms of a serious problem are observable to a layperson, fact-finder may infer knowledge warranting medical care)