West v. Commonwealth

Russell and Ann West (defendants) voluntarily took in and cared for Russell's disabled sister Lillian, who had Down syndrome and a heart condition; Russell later discontinued her participation in a health organization's services, and as her health declined, she developed severe bedsores, malnutrition, and other conditions, ultimately dying of sepsis and pneumonia caused by the untreated bedsores. Medical testimony attributed her death to the Wests' neglect, and a jury convicted Russell of second-degree manslaughter and Ann as a complicitor; they appealed.

Whether a caretaker who has a legal duty to care for another may be held criminally liable for a failure to act that results in that person's death.