State v. Small

Satonia Small (defendant) left her two young children unsupervised at night to go drink at a friend's house. A fire started in the apartment, and one child, S.S., later died from smoke inhalation and carbon monoxide poisoning. Small had previously pleaded guilty to child abandonment for a similar incident and had promised the court she would not leave her children unsupervised again. The state charged her with second-degree murder under a felony-murder theory based on cruelty to juveniles; a jury convicted her, and she appealed, arguing the fire — not her lack of supervision — directly caused the death.