State v. Patterson, 27 A.3d 374

Two-year-old victim placed in Patterson's care; he developed dehydration after liquids were restricted for days.
Patterson intermittently restricted fluids and attempted to discourage drinking from others' cups by placing hot sauce in a cup.
Victim died from dehydration; deputy medical examiner linked death to insufficient fluid intake.
Patterson, who has an IQ of 61, argues cognitive disability prevented forming required mental states for several offenses.
Trial court convicted Patterson of criminally negligent homicide, two counts of risk of injury to a child (situation and act prongs), and two counts of cruelty to persons; sentenced to ten years, suspended after five, with probation.
On appeal, court reverses only the act-prong risk of injury to a child conviction; remands for acquittal on that charge and resentencing; otherwise affirms.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence for criminally negligent homicide	Patterson's disability negates required negligence.	Disability precludes perceiving risk; cannot sustain conviction.	Sufficient evidence supports conviction.
Cruelty to persons requires specific intent	Culpability requires intent beyond general malice given disability.	Statute requires general intent; disability defeats culpability.	General intent suffices; evidence supports conviction.
Risk of injury to child, situation prong	Withholding fluids shows Willful/Unlawful endangerment of child.	Disability negates necessary mental state for recklessness under statute.	Evidence supports conviction under the situation prong.
Risk of injury to child, act prong (hot sauce incident)	Giving hot sauce constitutes act likely to impair health.	Insufficient proof that hot sauce would likely impair health; not proven.	Insufficient evidence to convict on the act prong; reversed and remanded for acquittal on that count.

State v. Na'im B., 288 Conn. 290 (2008) (wilful or unlawful placement of child in danger; awareness not required for situation prong)
State v. Sorabella, 277 Conn. 155 (2006) (risk of injury to a child requires general intent; acts with recklessness suffice)
State v. March, 39 Conn. App. 267 (1995) (act-prong elements include likelihood of injury; lack of actual injury not required)
State v. Salz, 26 Conn. App. 448 (1992) (criminal negligence standard is objective; substantial and unjustifiable risk)
State v. Gewily, 280 Conn. 660 (2006) (distinguishes between situation and act prongs of § 53-21(a)(1))
State v. Charles, 78 Conn. App. 125 (2003) (general intent defined; absence of specific intent when no extra result element)
State v. Davila, 75 Conn. App. 432 (2003) (testing act-prong elements; injury not required)
State v. Padua, 273 Conn. 138 (2005) (common knowledge can support reasonable inference of health harm)