People v. Woods
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After police found her severely-abused seven-year-old son alone on the streets of Chicago, Woods was convicted of four counts of aggravated battery of a child. The jury also concluded that the prosecution proved beyond a reasonable doubt that the aggravated battery was accompanied by exceptionally brutal or heinous behavior indicative of wanton cruelty. Woods’s paramour and codefendant, Richardson, was found guilty of the same offenses. Woods was sentenced to an aggregate term of 50 years.
On appeal, Woods argued that the jury instructions on accountability and parental accountability were directly conflicting instructions. The appellate court and Illinois Supreme Court affirmed. Any conflict in the required knowledge element in the parental accountability instructions was harmless error because Woods’s knowledge was not an essential element. Woods and Richardson were charged jointly on the theory that they acted together to brutalize and torture the child. Woods was found guilty and does not challenge the jury instructions regarding principal liability. Woods’s liability was not based on her passive presence; the evidence of her knowledge and participation in the abuse was clear and convincing.
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