An Indianapolis mother was wrongly convicted of neglect of a dependent child resulting in death, the Court of Appeals ruled Wednesday in reversing the jury’s verdict. Judges found evidence against Chelsea Taylor was insufficient to support the conviction.
Taylor was convicted of the Class A felony charge and ordered to serve four years in prison in the death of her 1-year-old son, J.N., in January 2012. J.N. had been left in the care of Taylor’s boyfriend, Ryan Worline, while Taylor was at work.
Worline was convicted of murder in the blunt-force trauma death of J.N., and Taylor, who was tried with Worline, was found guilty of neglect. But she argued there was no evidence that she was aware that J.N. needed medical care for injuries caused by Worline when she checked on the child upon returning home around 10 p.m. The child was dead the next morning.
Taylor also argued jurors were asked to draw inferences supported only by other inferences, and that a conviction may not rest on conjecture. The panel agreed.
“In this instance, the jury simply was not provided evidence that Taylor inflicted an injury, was present when injury was inflicted, heard the infliction of injury, or saw manifestations of an injury necessitating medical care,” Judge L. Mark Bailey wrote in Chelsea Taylor v. State of Indiana, 49A02-1402-CR-90.
“Although reasonable inferences may be drawn from evidence, it is the State’s burden to present evidence on each element of the charged crime from which those inferences may be drawn. Ultimately, a criminal conviction absent proof beyond a reasonable doubt on each element of the charged crime amounts to fundamental error. ...
“The inference-stacking without establishment of a predicate fact, which the prosecution invited and the State deems sufficient to withstand appeal, is not constitutionally adequate. The State failed to adduce sufficient proof to support Taylor’s conviction for Neglect of a Dependent.”