Can Extensive Injuries Be Sufficient Evidence to Convict a Defendant of Involuntary Manslaughter ?

In People v. Turner, 193 Ill. App. 3d 152, 153-55, 549 N.E.2d 1309, 140 Ill. Dec. 437 (1990), the defendant was charged with the murder of her two-year-old niece. Following a jury trial, the defendant was convicted of involuntary manslaughter. The evidence at trial showed that the little girl had extensive injuries, including facial and head injuries, fractured ribs, a fractured arm, a torn liver and diaphragm, and numerous scars on her entire body. Turner, 193 Ill. App. 3d at 154-55. After the defendant appealed, this court found that the evidence was sufficient to convict defendant of involuntary manslaughter beyond a reasonable doubt. Finally, in People v. Brown, 83 Ill. App. 2d 411, 228 N.E.2d 495 (1967), the defendant was convicted of involuntary manslaughter after his girlfriend's three-year-old son died from multiple traumatic impacts, as evidenced by large bruises over the victim's body, in addition to other injuries. Brown, 83 Ill. App. 2d at 414-15. the Brown court found that there was sufficient circumstantial evidence to convict the defendant of involuntary manslaughter beyond a reasonable doubt. Brown, 83 Ill. App. 2d at 415.