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Mother's Conviction for Poisoning Baby Reversed

People v. Brown Court: Supreme Court of California, Docket: S257631, Opinion Date: March 2, 2023. The Supreme Court reversed Defendant's conviction of the first-degree murder of her newborn daughter by poison, holding that the jury instructions were erroneous and that the error was prejudicial. At issue was whether there is a mental state component of first-degree poison murder when there is no question that the defendant acted with willfulness, deliberation, and premeditation. The Supreme Court held (1) to prove first degree murder by means of poison, the prosecution must show that the defendant deliberately gave the victim poison with the intent to kill the victim or inflict injury likely to cause death; and (2) the trial court's instructions erroneously did not include this element of first-degree poison murder, and the error was prejudicial, requiring remand.


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