Daron Washington v. State of Indiana

CourtIndiana Court of Appeals
DecidedDecember 30, 2025
Docket25A-CR-01169
StatusPublished

This text of Daron Washington v. State of Indiana (Daron Washington v. State of Indiana) is published on Counsel Stack Legal Research, covering Indiana Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Daron Washington v. State of Indiana, (Ind. Ct. App. 2025).

Opinion

FILED Dec 30 2025, 9:00 am

CLERK Indiana Supreme Court Court of Appeals and Tax Court

IN THE

Court of Appeals of Indiana Daron Washington, Appellant-Defendant

v.

State of Indiana, Appellee-Plaintiff

December 30, 2025 Court of Appeals Case No. 25A-CR-1169 Appeal from the Marion Superior Court The Honorable Jeffrey L. Marchal, Judge Trial Court Cause No. 49D31-2310-F1-28067

Opinion by Judge Weissmann Judges Bradford and DeBoer concur.

Court of Appeals of Indiana | Opinion 25A-CR-1169 | December 30, 2025 Page 1 of 10 Weissmann, Judge.

[1] One of Daron Washington’s twin four-month-old children, I.W., died while

severely malnourished, but her cause of death could not be determined with

medical certainty. Still, Washington was charged with and found guilty of two

counts of neglect of a dependent resulting in death: one based on his failure to

provide I.W. with adequate nutrition, and the other based on his failure to seek

medical care for the child. Due to double jeopardy concerns, however, the trial

court only entered judgment of conviction on the nutrition-based count.

[2] Washington appeals his conviction, arguing that the State failed to prove I.W.’s

death resulted from his failure to provide I.W. with adequate nutrition. Given

I.W.’s undetermined cause of death, we find the State failed to prove beyond a

reasonable doubt that I.W. would not have died but for her malnourishment.

We therefore reverse Washington’s conviction on the nutrition-based count and

remand to the trial court with instructions to enter judgment of conviction on

the medical-care-based count.

Facts [3] I.W. and her twin sister, K.W., were born prematurely at Eskenazi Hospital in

November 2022. The children spent 21 days in the neonatal intensive care unit

but were ultimately discharged from the hospital in stable condition. Upon the

children’s discharge, their mother and father—Tiera Crute and Washington,

respectively—were instructed to attend follow-up medical appointments and to

maintain routine pediatric care. Neither parent did.

Court of Appeals of Indiana | Opinion 25A-CR-1169 | December 30, 2025 Page 2 of 10 [4] One day in March 2023, Crute called Washington’s sister just before 9:00 a.m.

and reported that she had found I.W. unresponsive in the family’s home.

Washington’s sister in turn called 911, and police and paramedics were

dispatched to the scene. When they arrived, I.W. was in cardiac arrest. She also

appeared “emaciated” with sagging skin and protruding ribs. Tr. Vol. II, p. 114.

All attempts to revive I.W. were unsuccessful, and she was eventually

pronounced dead at Riley Children’s Hospital.

[5] When asked about the events leading up to I.W.’s death, Washington and

Crute provided inconsistent narratives. Washington stated that he fed I.W. a

bottle at 3:00 a.m. before laying her on a couch in the family’s home to sleep.

Then, at 7:00 a.m., he found I.W. unresponsive on the couch with no apparent

obstruction to her nose or mouth. Crute, however, stated that she fed I.W. a

bottle at 7:00 or 8:00 a.m. before I.W. fell asleep in Crute’s arms. Crute then sat

awake on the couch for roughly 30 minutes before noticing that I.W. was

unresponsive in her arms.

[6] Medical experts later determined that I.W. was severely malnourished when

she died. But her cause of death could not be determined with medical

certainty. Still, the State charged both Washington and Crute with two counts

of neglect of a dependent resulting in death. Count I specifically alleged that

they “failed to provide [I.W.] with adequate nutrition,” and Count II

specifically alleged that they “failed to seek medical treatment [for I.W.]” App.

Vol. II, p. 26. Crute pleaded guilty to a lesser offense, but Washington

proceeded to a bench trial on both charges.

Court of Appeals of Indiana | Opinion 25A-CR-1169 | December 30, 2025 Page 3 of 10 [7] At trial, the State presented the testimony of Dr. Amanda Paul, the forensic

pathologist who performed I.W.’s autopsy and further investigated her death.

Dr. Paul testified that I.W.’s cause of death “could not be determined.” Tr. Vol.

II, p. 197. According to Dr. Paul, an “undetermined” cause of death is different

from a “sudden unexplained death of an infant” (SUID), which often occurs

from an unknown cause during sleep. Id. at 179. But because Washington and

Crute gave conflicting accounts of the events leading up to I.W.’s death, Dr.

Paul did not have the information necessary to place I.W.’s cause of death in

the SUID category. In Dr. Paul’s words: “I really just don’t know, so I went

with undetermined. That was the best I could come up with.” Id. at 195.

[8] Despite I.W.’s severe malnourishment, Dr. Paul could not place I.W.’s cause of

death in the malnutrition category either. She explained:

I went with an undetermined cause of death because I -- because she was underweight, I couldn’t really say if it was enough of a malnourishment because if -- if she was malnourished enough to the point where I said this was definitely the cause of death, I would have listed the cause of death as malnutrition. But she’s just small enough that I don’t really know, but I think it does play a factor, I really do. But I just can’t know with certainty, which is what I’m supposed to do when I, you know, with medical certainty -- I don’t have that.

Id.

I’ve had cases that I have called malnutrition because they were significantly smaller than even [I.W.] was. But in this case, I -- you know, it just wasn’t enough that I could say with medical certainty that [malnutrition] was the cause of death, and that’s

Court of Appeals of Indiana | Opinion 25A-CR-1169 | December 30, 2025 Page 4 of 10 why I went with undetermined . . . in addition to the conflicting statements.

Id. at 201.

[9] The State also presented the testimony of Dr. Shannon Thompson, a child

abuse pediatrician who consulted with the Indiana Department of Child

Services after I.W.’s death. Dr. Thompson opined that I.W.’s malnutrition

likely “contributed to” her death, but she could not say it was the cause. Id. at

243. As Dr. Thompson explained: “That would be [Dr. Paul’s] role, and I

essentially agreed with her findings.” Id. But Dr. Thompson was confident that

I.W. would still be alive if Washington had sought medical care for her.

[10] Additionally, the State presented the testimony of Dr. James Lemons, a

neonatologist who treated I.W. while she was in the NICU following her birth.

Even “without knowing” the specific diagnosis for I.W.’s death, Dr. Lemons

testified that Washington’s delay in seeking medical care for I.W. “almost

certainly” resulted in her death. Id. at 98. And when asked whether he was

“absolutely certain,” Dr. Lemons stated: “We never say . . . always or never in

medicine.” Id.

[11] The trial court found Washington guilty of both counts of Level 1 felony

neglect of a dependent resulting in death. When explaining its verdict from the

bench, the court stated:

[Defense counsel] wants to argue that we don’t know why [I.W.] died. We -- we -- I agree with that, we can’t know that now.

Court of Appeals of Indiana | Opinion 25A-CR-1169 | December 30, 2025 Page 5 of 10 There may have been an underlying condition. But because you didn’t seek medical treatment, we couldn’t figure that out and attempt to fix it. That’s the problem.

Tr. Vol. III, p. 110. The court, however, only entered judgment of conviction

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Related

Bailey v. State
907 N.E.2d 1003 (Indiana Supreme Court, 2009)
Abney v. State
766 N.E.2d 1175 (Indiana Supreme Court, 2002)
Purvi Patel v. State of Indiana
60 N.E.3d 1041 (Indiana Court of Appeals, 2016)

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