336 A.3d 439
Vt.2025Background
- Stacey Vaillancourt, an experienced daycare provider, was convicted of involuntary manslaughter and cruelty to a child with death resulting after a six-month-old infant, H.B., died in her care.
- H.B. died from acute diphenhydramine (Benadryl) intoxication, with levels in her system many times higher than a therapeutic dose; the drug was not prescribed or administered by her parents or other caregivers.
- Evidence showed that Vaillancourt was the only person who could have administered the drug in the relevant timeframe, and as someone with childcare experience, she would have known the risks.
- The trial court denied Vaillancourt’s motion for acquittal, finding sufficient evidence to go to the jury; the jury convicted her on both counts.
- On appeal, Vaillancourt challenged the sufficiency of the evidence, argued the verdicts were inconsistent and violated double jeopardy, and contested admission of certain video evidence.
- The Vermont Supreme Court reviewed the legal standards for sufficiency of the evidence, inconsistent verdicts, double jeopardy, and evidentiary discretion, ultimately affirming her convictions.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of Evidence (both counts) | Evidence showed criminal negligence and intent | No direct proof of how diphenhydramine was administered; no proof of knowledge or intent | Sufficient evidence for both convictions |
| Inconsistent Verdicts | Counts are independent and not mutually exclusive | Mental states of charges are mutually exclusive | Verdicts are not inconsistent |
| Double Jeopardy | Legislature intended to allow multiple charges | Same conduct punished twice | No double jeopardy violation |
| Admission of Video Evidence | Videos were relevant to show causation | Videos were unduly prejudicial | No abuse of discretion; admissible |
Key Cases Cited
- State v. Viens, 186 Vt. 138 (proof required for involuntary manslaughter and criminal negligence)
- State v. Amsden, 194 Vt. 128 (willful exposure to risk under child cruelty statute)
- State v. Robitille, 210 Vt. 202 (sufficiency of evidence for involuntary manslaughter; circumstantial evidence)
- State v. Crepeault, 167 Vt. 209 (principle for inconsistent verdicts when one count is predicated on another)