Biddle v. Commonwealth

Brief Fact Summary.

After Defendant killed her baby, she was charged with first-degree murder. The baby died from malnourishment and dehydration as a result of Defendant’s conduct. After Defendant was convicted and sentenced to 20 years in prison, Defendant appealed.

Synopsis of Rule of Law.

According to Virginia law, manslaughter occurs when a defendant’s negligent conduct causes a person’s death and is not the direct consequence of the malicious omissions of the performance of Defendant’s duty.

Facts.

After Shirley Mae Biddle (Defendant) killed her baby, she was charged with first-degree murder. Evidence showed that her baby was malnourished and dehydrates at the time of her death, despite Defendant’s house having plenty of food. Another small child was found lying on newspapers with a wet and dirty diaper as well as a rash on her buttocks. Although Defendant’s baby was born weighing 5 pounds and 8 ounces, the baby weight 4 pounds and 5 one-half ounces. At trial, Defendant claimed that she fed her baby every day, but her baby would not drink it all. Defendant also claimed that her baby never cried when she was hungry. Defendant further claimed that she loved her baby and treated her the same way as her other children. Defendant’s husband claimed that Defendant’s children, including the dead baby, were from other men. After Defendant was convicted and sentenced to 20 years in prison, Defendant appealed.

Issue.

According to Virginia law, does manslaughter occur when a defendant’s negligent conduct causes a person’s death and is not the direct consequence of the malicious omissions of the performance of Defendant’s duty?

Held.

Yes. Manslaughter occurs when a defendant’s negligent conduct causes a person’s death. Also, the death must not be the direct consequence of the malicious omissions of the performance of Defendant’s duty. On appeal, Defendant argues that the trial court erred in convicting her of first-degree murder. Evidence showed that defendant was negligent in how she cared for her baby; however, the State failed to prove that Defendant’s conduct was willful and malicious, which is the determinative factor necessary for a murder conviction. As such, her judgment of conviction is reversed and remanded.

Discussion.

Virginia law differentiates between the degrees of murder; however, Virginia law does not define murder itself. According to common law, murder is a homicide committed with express or implied malice aforethought. In general, if a person’s death is the direct consequence of the malicious omission of the performance of a duty, then it is considered murder. For example, a mother failing to feed her baby is considered murder. However, if the defendant’s conduct is not willful and the death results from an omission in the performance of a Defendant’s duty, then it is manslaughter.