State v. Layton
1512005902
| Del. Super. Ct. | Dec 6, 2017Background
- Infant Aiden, born drug-dependent, suffered multiple traumatic injuries at ~3 months, was hospitalized and later taken off life support and died; DFS and Family Court found abuse/neglect and removed custody.
- Parents Doyle Hundley and Casey Layton were the only caretakers during the relevant period; Hundley was alleged to have inflicted the injures.
- Layton is charged with Murder by Abuse, Murder by Neglect (11 Del. C. § 634), and Endangering the Welfare; state later nolle prosequied the Murder by Abuse charge.
- Layton moved to dismiss the Murder by Neglect count as unconstitutionally vague; State moved to admit various prior-bad-act evidence (drug use during pregnancy, postnatal drug abuse, hiding the child from DFS).
- Court examined statutory definitions (‘‘neglect,’’ ‘‘necessary care,’’ ‘‘previous pattern’’) and applicable evidentiary rules (D.R.E. 404(a)/(b), Getz/Deshields framework) to resolve vagueness and admissibility issues.
Issues
| Issue | State's Argument | Layton's Argument | Held |
|---|---|---|---|
| Whether 11 Del. C. § 634(a)(2) (murder by neglect via previous pattern) is unconstitutionally vague | Statute gives fair notice: it criminalizes recklessly causing a child’s death by engaging in a pattern of neglect | Statute is vague because subsection (2) lacks an explicit causal-link word and could convict for prior neglect unrelated to death | Denied dismissal — statute not void for vagueness; ordinary person would understand prior pattern must be tied to the death |
| Whether prior bad-act evidence must be excluded under D.R.E. 404(a)/(b) | Prior acts showing pattern of neglect are necessary to prove § 634 elements, so admissible in State’s case-in-chief; some pregnancy/postnatal drug-use evidence admissible under 404(b) for state of mind/neglect | Evidence is propensity evidence; some allegations are unproven, too remote, or prejudicial | Granted in part: evidence of postnatal neglect and failures to seek/provide care admissible to prove pattern and recklessness; drug use during pregnancy and infant’s drug-dependence admissible under 404(b) for state of mind; hiding DFS case or related conduct excluded as too remote/prejudicial |
| Temporal scope of admissible prior-act evidence | Only acts from Aiden’s birth forward are necessary to prove the pattern element; in-utero acts are less probative of pattern | Argued some prenatal acts are relevant to motive/state of mind but risk prejudice | Court limited element-proving evidence to postnatal acts; prenatal drug use allowed under 404(b) but not as element-proof |
| Causation standard for reckless conduct under § 634 | Reckless (but-for limited by risk-known) causation suffices; omission can satisfy mens rea given high parental duty | Argued she was passive/non-actor or acted under duress; causation/ mens rea uncertain | Court: but-for causation with statutory limitation (10 Del. C. § 263) applies; jury to decide recklessness and causal risk given proper instructions |
Key Cases Cited
- Hoover v. State, 958 A.2d 816 (Del. 2008) (void-for-vagueness analytical framework)
- Taylor v. State, 777 A.2d 759 (Del. 2001) (other-crimes evidence must be relevant to State's prima facie case to be admitted in its case-in-chief)
- Getz v. State, 538 A.2d 726 (Del. 1988) (factors for admitting 404(b) evidence)
- Deshields v. State, 706 A.2d 502 (Del. 1998) (factors for balancing probative value vs. prejudice under Rule 403)
- Bullock v. State, 775 A.2d 1045 (Del. 2001) (but-for causation principle and limitations for reckless or negligent conduct)
- Fraga v. State, 898 N.W.2d 263 (Minn. 2017) (parental omission can establish pattern of neglect and satisfy element of charged offense)
- Muehe v. State, 646 N.E.2d 980 (Ind. Ct. App. 1995) (duty to remove child from abusive caregiver; failure can constitute neglect)