People v. Mattison
Court: Appellate Division of the Supreme Court of the State of New York; April 18, 1996; New York; State Appellate Court
An appeal was made by defendant Mikoll following her conviction for second-degree assault, stemming from an incident on August 30, 1993, where her 22-month-old daughter sustained severe scalding burns. Upon arrival of a volunteer rescue squad, they found the child with second and third-degree burns to multiple areas of her body. Defendant provided several inconsistent accounts regarding the situation, claiming she briefly left the child alone in the bathroom while attending to her other daughter, only to return upon hearing the child scream. Following the trial, a jury found Mikoll guilty of recklessly causing serious injury to her child. She was sentenced to a term of 2 to 5 years in prison. On appeal, Mikoll argued that the circumstantial evidence was legally insufficient to support her conviction. The court, however, upheld the jury's verdict, emphasizing that it must determine whether a rational person could reach the same conclusion based on trial evidence viewed favorably towards the prosecution. The court noted that the evidence, including testimony from medical experts and inconsistencies in Mikoll's statements, indicated that the burns were not accidental but were inflicted by someone—specifically, the defendant—who had sole access to the child at the time. The testimony regarding the child’s inability to reach the sink and turn on the hot water further supported the conviction. Ultimately, the appellate court affirmed the judgment, finding sufficient proof of guilt beyond a reasonable doubt.