Common Law and Duty

Biddle v. Commonwealth and Davis v. Commonwealth are two cases that portray different interpretations and application of the law with regards to imputability in criminal law. These cases provide a different view of an individual's responsibility with regards to the level of care or responsibility for a parent than for a child. An analysis of the court ruling in each of these cases helps in understanding the required level of care or responsibility. This is primarily because the court decisions were based on the level of legal duty imposed by law on the parties. Even though the cases are relatively similar, there were differences in the rulings because of the differences in the legal duty of the parties involved.

Overview of the Cases

In Biddle v. Commonwealth, Shirley Mae Biddle was charged with first-degree murder of her baby on the premise that the baby was malnourished, dehydrated and had not eaten for a couple of days. When police detectives visited Biddle's home, they not only found the baby's body in severe state of malnutrition but also found blood spots on the diaper and her private parts. There was another infant lying on a newspaper in a bassinet with wet diapers and rash on her buttocks. Medical testimony showed that the deceased baby was born healthy as she weighed 5 pounds and 8 ounces at birth. Upon death, the baby weighed 4 pounds and 5 and one-half ounces and had a complete empty intestinal tract and stomach. The medical examiner therefore concluded that the baby was not fed well.

During trial, the defendant (Biddle) testified that she fed the baby on a daily basis, but she would not drink all the milk given to her. Biddle also stated that the baby never cried because she was hungry and never mistreated her or treated her differently from the other children. On the other hand, Biddle's husband accused her of having the baby and the other children by other men. The defendant was convicted and sentenced to 20 years in prison, a ruling that she appealed. The appeal was granted on the premise that the Commonwealth had not proved beyond reasonable doubt that Biddle acted deliberately or maliciously to cause the death of her baby. Consequently, the court argued that the conviction of first-degree murder was not supported by the evidence and reversed the conviction and remanded the case for a new trial.

In Davis v. Commonwealth, Mary V. Davis was convicted of unintentional manslaughter of her mother and sentenced to 10 years in prison. A paramedic from the Lynchburg Fire Department responded to a call from a house in Monroe Street that was occupied by Davis and her mother, Emily B. Carter. Upon arrival to the house, the paramedic found Carter lying on a bed on a cold day while there was not heat in her room. The source of heat in this room was a tin heater that was not being used at this time. Additionally, there was only a can of juice, two cans of soup, cheese, and an open box of macaroni in this house. One of the two trash cans behind the house had approximately 12 empty cans of vegetable while the other was filled with empty beer cans. The defendant's (Davis) upstairs room was found to have a supply of firewood, a functioning stove, and a color television. When Carter was admitted to a hospital that evening, she was severely ill and unstable. She died three days later because of severe malnutrition, low body temperature, and bilateral pneumonia. In addition, she was found to have a blood stream infection, several rib fractures, and a skull laceration. Based on a report from a forensic pathologist, the main causes of Carter's death were pneumonia and exposure to a chronic state of starvation.

During trial, Davis contended that the evidence in the case failed to establish whether she had a legal duty to care for her mother though she recognized the accuracy of ignoring legal principles. She argued that the evidence in this case only proved a moral duty to care for her mother rather than a legal one. These claims were dismissed by the court on the premise that the evidence showed that she accepted sole responsibility for the complete care of her mother, which essentially became a full-time occupation for her. Her legal duty for the total care of the deceased is attributable to the fact that she was not a volunteer as shown by the existence of an implied contract between the two parties. In its ruling, the court found Davis culpable of involuntary manslaughter because she had neglected Carter for a long period of time. The court argued that Carter's death could have been prevented if she was not starved and frozen to death as demonstrated by the scientific evidence in the case. Consequently, the court upheld the trial court's ruling on the premise the Davis breached her legal duty of care, which eventually resulted in the death of her mother, Carter.

Differences in the Courts' Decisions

As previously mentioned, the court reached different decisions in these two cases despite relatively similar incidents that involved different parties. In Biddle v. Commonwealth, the case was centered on whether the defendant committed negative acts that would warrant a first-degree murder sentence. Based on common law, an individual is convicted of murder if he/she acts with pre-determined or implied malice. This implies that the general rule in common law is that conviction of murder should be supported by direct consequence of malicious omission of performance of a legal duty. Therefore, if the malicious omission is not deliberate and is a result of neglect, it is manslaughter rather than murder (Dripps, Boyce & Perkins, 2013). The court focused on examining whether Biddle acted deliberately or not to cause the death of her baby. This essentially means that conviction of a murder requires the proof of malice for negative acts or omission of performance of a legal duty.

On the other hand, in Davis v. Commonwealth, the main focus of the case was on whether the defendant (Davis) had a legal duty to care for her mother and whether she performed her duty as required by law. A legal duty such as the duty of care is usually imposed by law or generated by a contract including an implied contract. Similar to Biddle v. Commonwealth, the court examined whether there was malicious omission of the performance of duty or criminal negligence in a manner that would result in death. Davis legal duty for total care of her mother emerged from an implied contract since she accepted sole responsibility to care for her.

The court reached two different decisions because of the proof of malice in both cases, which is required in order to convict a person of murder. Biddle had clearly neglected her baby, was careless, and was apathetic in performing her duties not only to the baby but other family members as well. Since her careless, neglect, and indifference in performing her duties extended to other members of the family, her negative acts towards the baby were not malicious. In this case, she did not maliciously target the baby but treated her just like she treated other members of her family. While she had the responsibility to take care of her baby, she was struggling in how to treat members of her family including the other infant who was found lying on newspapers in a bassinet. There was lack of sufficient evidence that could prove beyond reasonable doubt that Biddle acted maliciously or deliberately to withhold food and other necessities from the infant. Based on the court's interpretation of common law rule relating to murder, the intention to kill and deliberate or malicious acts must be proven beyond reasonable doubt for one to be convicted of murder. This malicious element that constitutes a murder can be implied or expressed (Hendel, 2006). The evidence in Biddle v. Commonwealth was simply criminal negligence or carelessness without willful or deliberate malicious acts that could constitute a murder as required by common law. Similarly, conviction of murder in Davis v. Commonwealth required proof of malice to constitute a murder. The court utilized the same grounds as in Biddle v. Commonwealth to determine whether the defendant acted maliciously and eventually caused the death of her mother.

Apart from the proof of malice, the court reached two different decisions in these cases because the defendants had been convicted differently in the trial courts. Biddle had been convicted of first-degree murder despite the lack of sufficient evidence whereas Davis had been convicted of involuntary manslaughter. Since the case facts were relatively similar and the cases involved application of the same common law rule, it was vital to ensure that the rulings reflected effective interpretation of relevant laws, hence, the different court rulings.

Inconsistency in Rulings

Even though the courts reached two different rulings in these cases, the two decisions are not inconsistent with one another. This is primarily because the trial courts had given two different convictions on issues that appeared similar and involved application of the same general rule in common law. Biddle could not be convicted of a first-degree murder for criminal negligence in the performance of a legal duty while Davis is convicted of involuntary manslaughter. If the Supreme Court of Virginia upheld Biddle's decision, the court's ruling could have been inconsistent with Davis' decision. Therefore, by reversing the ruling and remanding the case for a new trial in Biddle v. Commonwealth, the court ensured consistent interpretation and application of common law rule relating to murder and manslaughter. Actually, the ruling in Biddle v. Commonwealth was utilized as a legal principle in determining Davis v. Commonwealth, which implies that there were no inconsistencies in these two different court decisions (Justia -- US Law, n.d.).

While the rulings in these cases appear different, they are consistent with one another since they ensure that proof of malice must be demonstrated for one to be convicted of murder. The consistency between these two decisions is also evidenced in the fact that the application of the same law to relatively similar cases would generate the same interpretation and ruling. In both cases, each of the defendants had an implied legal duty to care for members of their family. These defendants breached this legal duty through criminal negligence in the performance of the duty and contributed to the deaths of their family members. Since their actions were not malicious or deliberate, the ideal conviction based on common law would be involuntary manslaughter rather than murder. Therefore, the eventual outcomes of the two different decisions in these cases were convictions of involuntary manslaughter because of criminal negligence rather than murder.

Level of Care/Responsibility

As previously mentioned the legal duty of care is usually enforced by law or emerges from a contract including an implied contract between two parties. One of the issues in these cases is the duty of care, which was first determined before examining how the defendants performed their legal duties. Even though the decisions in these cases were different, they do not imply that there is a different level of care or responsibility for a parent than for a child. This is proven by various reasons relating to the cases and their determination.

First, there is not different level of care or responsibility for a parent than for a child because the courts' decisions were not based on examining who was eligible for care. When examining case facts and evidence, the court did not examine who was receiving the care but focused on the existence of a legal duty and whether that duty was performed. In essence, the decision in Biddle v. Commonwealth was based on whether Biddle acted maliciously or intentionally to deny her baby food in a manner that resulted in the death of the baby. On the other hand, the decision in Davis v. Commonwealth was based on whether Davis' neglect of taking care of her mother was fueled by malicious intentions. In essence, the main issue was performance of the legal duty rather than who was receiving care. Therefore, these two different decisions do not imply that there are different levels of care or responsibility for a parent or child, but performance of legal duty.

Secondly, the cases were primarily determined on the premise of criminal negligence of the performance of the legal duty arising from the implied contract. Criminal negligence is basically defined as a failure in law to act reasonably as a reasonable person in the same circumstances would do (Hobart Community Legal Service Inc., 2013). In this regard, individuals should carry out their affairs and activities to the standard required of the reasonable individual. When making the decisions, the court examined the defendants' responsibility in acting reasonably rather than who was receiving care. These individuals were primarily convicted based on criminal negligence (i.e. failure to provide reasonable care) instead of the level of care or responsibility for a parent and a child.