Delaware's Supreme Court on Thursday overturned the conviction of a 17-year-old girl in a school bathroom attack that left a 16-year-old classmate dead.
The girl was adjudicated delinquent for criminally negligent homicide by a Family Court judge last year and sentenced to six months in a juvenile facility for the April 2016 death of Amy Joyner-Francis.
An autopsy found that Joyner-Francis, who had a rare, undetected, heart condition, died of sudden cardiac death, aggravated by physical and emotional stress from the fight at Howard High School of Technology in Wilmington. Cellphone video of the attack, which gained national attention, shows Joyner-Francis struggling to fight back and escape as she is repeatedly hit and kicked in the head while her assailant holds on to her hair.
In a unanimous ruling, the Supreme Court agreed with defense attorney John Deckers that no reasonable fact-finder could have found that the girl acted with criminal negligence. Even if she did, the court said, it would be unjust to blame her for Joyner-Francis' death given how unforeseeable it was that the fight would lead to a young teen dying of cardiac arrest.
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The Associated Press has not published the name of the girl because she is a juvenile. The Supreme Court in its ruling referred to the defendant using the pseudonym "Tracy," while referring to Joyner-Francis as "Alcee."
The justices said a person can't be held responsible for criminally negligent homicide unless her failure to perceive the risk of death was a "gross deviation from what a reasonable person would have understood." No reasonable fact-finder could conclude that the attack, which inflicted only minor injuries on Joyner-Francis, posed a risk of death so great that her assailant was grossly deviant for not recognizing it, the court concluded.
While the Family Court judge said the girl should have realized that her attack might have deadly consequences because of the close confines of the bathroom, with its tile floor and hard fixtures, the Supreme Court said Joyner Francis' death had nothing to do with those risks, and they were too far removed from the way that she died to blame her assailant for her death.
Deckers did not immediately return email and phone messages. A spokesman for the attorney general's office said prosecutors are disappointed but respect the court's decision.
While overturning the Family Court ruling, the justices did not excuse the girl's behavior.
"Our observations about the feebleness of Tracy's blows and the lack of impact they had on Alcee's death are not intended to minimize the wrongfulness of Tracy's behavior," Justice Gary Traynor wrote for the court. "The record amply supports the Family Court's portrayal of the encounter as an 'attack' and an 'act of violence' that Tracy inflicted for nothing more than 'a perceived slight on social media.'"
The attacker and a 17-year-old co-defendant were convicted of conspiracy for planning the attack. A third defendant was acquitted of conspiracy.
Prosecutors traced the conflict to an online group chat the day before the attack, when Joyner-Francis had offered advice to a friend about a problem involving a boy, telling her friend to "just be careful." Joyner-Francis warned that someone might "switch up," or betray another person. A police detective said the assailant thought Joyner-Francis was talking about her as the possible traitor.
A Snapchat posting by one of the defendants that same day shows Joyner-Francis talking to her alleged assailant in the bathroom, purportedly to try to defuse the situation. The posting notes that the girl later convicted of homicide was "bouta fight her," followed by several emojis indicating that a person was laughing so hard she was crying.