State of Tennessee v. Shalonda Weems

State of Tennessee v. Shalonda Weems, No. M2018-02288-SC-R11-CD (Sept. 30, 2020).

Written By: Hannah Jones, Associate Editor

Shalonda Weems was a single mother with three small children. Her youngest child, Kar’mn, was six months old in March of 2005. On March 2, 2005, Weems observed Kar’mn acting and eating normally. Kar’mn was sick with a fever on March 1, but Weems noted that Kar’mn was feeling better. On the morning of March 3, Weems found Kar’mn barely breathing and turning blue. Kar’mn passed away later that morning.

Dr. Hawes performed Kar’mn’s autopsy investigation and concluded that Kar’mn’s cause of death was “dehydration and malnutrition with interstitial pneumonitis as a contributory cause of death.” When Dr. Hawes performed the autopsy, Kar’mn had no food or waste products in her body, which was an indicator of malnutrition. Some other signs of malnutrition and dehydration were loss of fat around internal organs, sunken eyes, a sunken fontanel, and dry and doughy skin. Dr. Hawes also noted that Kar’mn’s low level of fat around her organs indicated that she was not receiving proper nutrition for a period of time prior to her death.

Years later, Weems was indicted for aggravated child neglect and felony murder. After the State presented its proof, the defense moved for a judgment of acquittal for aggravated child neglect, arguing that the State failed to prove that Weems “knowingly” neglected Kar’mn – which was an essential element of the crime. The trial court denied this motion so that the jury could decide the issue of neglect. The jury then found Weems guilty of aggravated child neglect and reckless homicide. Weems then renewed her motion for acquittal on both counts, and the trial court granted the motion for the aggravated child neglect charge, finding that the evidence of Weems’s knowledge was insufficient. The Court of Criminal Appeals affirmed the trial court’s grant of the motion for judgment of acquittal and agreed that the evidence was insufficient.

On appeal, the issue presented to the Tennessee Supreme Court was whether the Court of Criminal Appeals erred by substituting its own judgments for those of the jury, determining the weight of witness testimony, failing to view evidence most favorably to the prosecution, and failing to disregard countervailing evidence.
The proper inquiry in reviewing the lower courts’ decisions centered around whether any rational trier of fact could have found the essential elements of the crime beyond a reasonable doubt, with all inferences in favor of the prosecution. While Weems was adamant that she fed Kar’mn regularly up until her death, the autopsy contradicted that claim. The conditions present at Kar’mn’s death appeared chronic, indicating that something had been happening over a period of time.

Ultimately, the Tennessee Supreme Court held that the jury could have made a reasonable inference that Weems’s statements were not credible based on the presented medical and scientific evidence. Therefore, a reasonable jury could have concluded that Weems knowingly neglected Kar’mn by not properly feeding her and therefore causing Kar’mn’s death. The Supreme Court reversed the lower courts’ decisions. As a result, the Court reinstated Weems’s conviction for aggravated child neglect.

One implication from this decision is the importance placed on inferences drawn from scientific evidence. The lower courts both did not believe that knowledge could not be reasonably proven through the scientific evidence, but the result on appeal indicates that a jury may reasonably draw inferences from the scientific evidence to establish elements of the crime. The defendant need not state that neglect occurred for the jury to make such an inference.

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