People v. Myers
2022 IL App (4th) 200592-U
| Ill. App. Ct. | 2022Background
- Two-year-old Ta’naja Barnes was found dead on Feb. 11, 2019; autopsy concluded immediate cause: hypothermia due to environmental neglect, with chronic malnutrition and dehydration as significant contributing factors.
- At death she weighed 21 lbs; autopsy showed healed scars indicating prior nonaccidental injuries and thymic atrophy consistent with prolonged starvation/dehydration.
- Home conditions: no running water, filthy interior, mattress without bedding, feces present; furnace reportedly turned off the night before, outside temperatures below freezing, and no working heater in Ta’naja’s bedroom.
- DCFS had previously removed and then returned Ta’naja to the household after parents (Davis and Myers) completed services; staff had treated Myers as a parental figure during supervised visits.
- Jury convicted Anthony Myers of knowing first-degree murder (720 ILCS 5/9-1(a)(2)); trial court sentenced him to 30 years; Myers appealed claiming insufficient evidence of the mens rea required for knowing murder, seeking conviction reduction to endangering the life or health of a child (720 ILCS 12C-5).
- Appellate court affirmed, holding a rational trier of fact could find Myers knew his acts created a strong probability of death or great bodily harm.
Issues
| Issue | Plaintiff's Argument (People) | Defendant's Argument (Myers) | Held |
|---|---|---|---|
| Whether evidence proved Myers had the mens rea for knowing first-degree murder (knowledge that his acts created a strong probability of death or great bodily harm). | Evidence (malnutrition, dehydration, hypothermia, removal of heater, in loco parentis status) permitted inference Myers was consciously aware the risk was strongly probable. | Evidence showed at most a risk of harm or neglect; not proof beyond a reasonable doubt that Myers knew his conduct created a strong probability of death or great bodily harm; reduction to endangerment warranted. | Affirmed. Viewing evidence in the light most favorable to the State, a rational jury could find beyond a reasonable doubt Myers had the requisite knowledge for knowing first-degree murder. |
Key Cases Cited
- People v. Collins, 214 Ill. 2d 206 (Ill. 2005) (defines 'endanger' as creating a probability of harm and explains probability standard).
- People v. Banks, 161 Ill. 2d 119 (Ill. 1994) (affirmed murder conviction where defendant’s affirmative acts caused victim’s starvation/hypothermia).
- People v. Stanciel, 153 Ill. 2d 218 (Ill. 1992) (criminal liability may arise from omissions when a legal duty to act exists).
- People v. Davis, 35 Ill. 2d 55 (Ill. 1966) (discusses relative degrees of probability in mens rea concepts).
- Mid-American Lines, Inc. v. Industrial Comm’n, 82 Ill. 2d 47 (Ill. 1980) (elements for in loco parentis status; assuming parental functions/duties).
- Mowbry v. Mowbry, 64 Ill. 383 (Ill. 1872) (historic discussion of presumption when non-parent assumes parental relationship).