Jones v. United States case brief

Jones v. United States case brief summary
308 F.2d 307 (1962)

CASE SYNOPSIS

Defendant appealed from a jury verdict in the lower court (District of Columbia) finding defendant guilty of involuntary manslaughter, asserting insufficient evidence, or alternatively, plain error, in instructing the jury of her legal obligation to provide food and necessities to a baby in her care.

CASE FACTS
Appellant argued there was insufficient evidence to warrant a jury finding of breach of duty, or alternatively, plain error in failing to instruct the jury that it must first find that appellant was under a legal obligation to a baby in her care before finding her guilty of manslaughter in failing to provide food and necessities.

DISCUSSION

• The reviewing court found the first contention meritless but reversed on the second. 
• The court stated that criminal liability could be found for breach of a statutory duty where there was a certain status relationship, where one had assumed a contractual duty, and where one had secluded a helpless person so as to prevent others from aiding. 
• Since a finding of legal duty was the critical element of the crime charged, failure to instruct the jury concerning it was plain error. Further, it was obvious error to instruct the jury without notice to counsel.

CONCLUSION
Reversed, because a finding of legal duty was the critical element of the crime charged so that failure to instruct the jury concerning it was plain error, and, further, it was obvious error to instruct the jury without notice to counsel.

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