State Of Washington, V. Cody James Shields, 83803-2

Infant Lucian (born Aug 25, 2015) died Dec 8, 2015; autopsy concluded death from chronic malnutrition and dehydration and manner of death homicide.
Parents Cody Shields and Brittany Daniels cared for Lucian; evidence showed prolonged feeding problems, frequent unsupervised bottle propping by Shields, and social-media messages expressing anger toward the child.
Daniels pleaded guilty to second-degree manslaughter in Dec 2019 and began serving sentence before Shields’ trial; the court allowed testimony that she had “resolved her case” but barred the word “guilty.”
At trial the State relied on Facebook messages and the medical examiner’s testimony; the court instructed the jury that criminal negligence may be established if a person acted intentionally, knowingly, or recklessly, and defined those mental states.
The jury convicted Shields of second-degree manslaughter; he was sentenced to 24 months custody plus 18 months community supervision and appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Jury instruction that criminal negligence is satisfied by intentional/knowing/reckless conduct	Instruction correctly states the law under RCW 9A.08.010(2); higher culpability proves lower	Instruction was misleading/confusing because manslaughter requires criminal negligence, not higher mens rea	Affirmed; instruction correct per RCW 9A.08.010(2) and supported by law
Sufficiency of the information (charging document)	Information gave fair notice of second-degree manslaughter elements	Information was deficient for not stating State would prove intent/knowledge/recklessness	Affirmed; information need not define mental-state substitutes and fairly alleged criminal negligence
Admission of testimony that Daniels “resolved her case”	State allowed to elicit to avoid surprise and show potential bias; impeachment matters are admissible	Testimony irrelevant and prejudicial because it invited juror inference about Daniels’ deal	Any error harmless; court instructed jury to disregard and outcome not materially affected
Prosecutorial argument suggesting higher culpable mental state	Closing argument reflected the law and matched jury instructions	Misconduct because it emphasized higher mens rea not charged	No misconduct; prosecutor’s statements were legally accurate and aligned with instructions

State v. Levy, 156 Wn.2d 709 (review standard for jury instructions)
State v. Irons, 101 Wn. App. 544 (jury instructions sufficient if supported by evidence and allow parties’ theories)
State v. Acosta, 101 Wn.2d 612 (higher mental state establishes lower mental states)
State v. Johnson, 180 Wn.2d 295 (information need not include definitions of elements)
State v. Bourgeois, 133 Wn.2d 389 (State may elicit plea-agreement evidence in chief to "pull the sting")
State v. Stein, 144 Wn.2d 236 (presumption that juries follow limiting instructions)