Williams v. State (2007)

In Williams v. State, 235 S.W.3d 742 (Tex. Crim. App. 2007), the Court found that a mother who left her two daughters in a room with a lit candle under another adult's supervision was not criminally responsible for the children's burning deaths because it was not reasonably foreseeable: (1) that the other adult would forget to blow the candle out before falling asleep; (2) that a sheet or clothing would then fall on the burning candle; (3) that the other adult would not be able to get children out of the house after the fire started. Id.