People v. Knoller

Knoller and her husband kept two large, dangerous, aggressive dogs despite explicit veterinary warnings and roughly thirty prior incidents of the dogs being out of control, and the dogs ultimately attacked and killed a neighbor; the jury convicted Knoller of second-degree murder on an implied-malice theory, the trial court granted a new trial finding she lacked awareness of a high probability of death, and the Court of Appeal reversed that grant, defining implied malice as requiring only awareness of a risk of serious bodily injury.