AI Generated Opinion Summaries

This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.

Facts

• The Defendant, Sandra Greenwood, was found guilty of neglect resulting in the death of her developmentally disabled adult son, Jared, who was entirely dependent on her for care. Jared died under her supervision in their home, which was filled with trash, feces, and had severe hygiene issues. Jared suffered from extensive pressure ulcers, some exposing bone, indicating long-term neglect. The Defendant had previously been employed by LINKS, a care agency, to provide care for Jared but failed to renew the necessary medical assessment for him, leading to the lapse of their care contract (paras 2-7).

Procedural History

• Appeal from the District Court of San Juan County, John A. Dean, Jr., District Judge.
• Certiorari Denied, January 4, 2012, No. 33,323.
• Released for Publication February 21, 2012.

Parties' Submissions

• Appellant (Defendant): Argued that the jury instructions were confusing, the Act was not intended to apply to her house or Jared as a "resident," the Act is void for vagueness, the State failed to present sufficient evidence for a conviction, and the district court erred in not holding mid-trial voir dire due to significant media exposure (para 11).
• Appellee (State): Contended that the Defendant was subject to the Act because Jared was her son and she had been under contract for Jared's care, which she allowed to lapse. The State also argued that the Defendant's home was a care facility under the Act and that the Defendant was the caregiver under the Act for Journey, Jared's sibling, at the time of Jared's death (para 29).

Legal Issues

• Whether the jury instructions were confusing and misdirected the jury.
• Whether the Act was intended to apply to the Defendant's house as a care facility and to Jared as a "resident."
• Whether the Act is void for vagueness on the facts of the case.
• Whether the State presented sufficient evidence for a conviction.
• Whether the district court erred in not holding mid-trial voir dire due to significant media exposure (para 11).

Disposition

• The court affirmed the Defendant's conviction for neglect of a resident resulting in death under the Resident Abuse and Neglect Act (para 62).

Reasons

• The court rejected the Defendant's constitutional vagueness attack, interpreting the Act to cover the Defendant's grossly negligent failure to prevent Jared's death. The court found that the jury instructions, while potentially confusing, did not constitute fundamental error. It determined that the Act applied to the Defendant's situation, as her home qualified as a care facility and Jared as a resident under the Act. The court also found sufficient evidence to support the conviction, noting the Defendant's acknowledgment of Jared's total dependence on her and the severe conditions leading to his death. The court concluded that the Act was not void for vagueness, providing fair notice and sufficient standards to avoid arbitrary enforcement. Lastly, the court found no abuse of discretion in the district court's decision not to conduct mid-trial voir dire following media coverage of the trial (paras 12-62).