State v. Bolze-SannAnnotate this Case
An infant died from respiratory failure after becoming trapped between the mattress and footboard of an adult bed at the home of Defendant, his daycare provider. After a jury trial, Defendant was convicted of involuntary manslaughter and aggravated endangering a trial. The court of appeals affirmed Defendant’s convictions. The Supreme Court affirmed, holding (1) the district court properly denied Defendant’s pretrial motion to dismiss because the motion was untimely; (2) sufficient evidence supported Defendant’s convictions; (3) the district court’s instructions to the jury on two means of committing involuntary manslaughter did not violate Defendant’s right to a unanimous jury verdict; (4) the district court did not clearly err by declining to define “imminence” for the jury; (5) the district court did not err in refusing to issue Defendant’s limiting instruction regarding the evidentiary value of a state regulation; and (6) the district court’s response to the deliberating jury’s question was harmless error.