Young v. State, 358 S.W.3d 790

Appellant Abigail Young was convicted of recklessly causing serious bodily injury to Emma, a child age under 15, based on alleged omissions of medical attention, care, protection, and supervision.
Emma Thompson, four years old, died from blunt abdominal trauma with numerous injuries; autopsy revealed genital trauma and other serious injuries not consistent with a fall or CPR.
Appellant, a registered nurse, allowed Coe—with a criminal history and prior CPS concerns—to supervise Emma, despite warnings and supervised access restrictions.
Evidence showed Appellant delayed medical treatment despite Emma's worsening condition and repeatedly lied about Coe's access to Emma; herpes type 2 was discovered in Emma, raising sexual-abuse concerns.
The State charged intentional/knowing injury by omission; the jury was instructed on a lesser-included offense of reckless injury to a child and convicted Appellant under that theory.
The trial court sentenced Appellant to 20 years' confinement and a $10,000 fine; judgment affirmed on appeal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence for recklessness mens rea	Young contends evidence insufficient for recklessness	State argues circumstantial and direct evidence supports recklessness	Sufficient evidence supports recklessness under all theories
Exclusion of Dr. Gilhousen testimony	Exclusion violated rights by omitting critical defense evidence	Rulings were within trial court discretion; non-constitutional error harmless	Exclusion harmless; no reversal on this basis
Sixth Amendment complete defense right	Exclusion precluded a vital part of defense	Defense still presented through other witnesses and closing; no violation	Harmless error; no due-process violation Whitney-like
Ex post facto/Brooks standard applicability	Abolition of factual sufficiency review violates ex post facto protections	Brooks is a standard-of-review issue, not a change in offense or punishment	Brooks does not violate ex post facto; standard preserved

Jackson v. Virginia, 443 U.S. 307 (U.S. 1979) (legal sufficiency standard for criminal verdicts)
Brooks v. State, 323 S.W.3d 893 (Tex. Crim. App. 2010) (abrogation of factual sufficiency review on appeal)
Guevara v. State, 152 S.W.3d 45 (Tex. Crim. App. 2004) (evidence of concealment as circumstantial proof of guilt)
Hart v. State, 89 S.W.3d 61 (Tex. Crim. App. 2002) (requirement of reliable inference for mental state by circumstantial evidence)
Ledesma v. State, 677 S.W.2d 529 (Tex. Crim. App. 1984) (culpable mental state may be inferred from surrounding circumstances)
Tillman v. State, 354 S.W.3d 425 (Tex. Crim. App. 2011) (standard for evaluating reliability of expert testimony under Rule 702)