## Facts

- Casey Campbell lived with her young daughter, H.C., and Campbell’s live-in boyfriend, Floid Boyer.
- In 1992, H.C. was removed from Campbell’s care after Boyer severely injured H.C.
- H.C. was later returned to Campbell’s care even though Campbell continued living with Boyer.
- On June 27, 1995, Campbell left H.C. in Boyer’s care.
- While in Boyer’s care, H.C. suffered second- and third-degree burns later determined to cover about 18% of her body.
- Boyer claimed he tripped and spilled hot coffee on H.C., causing the burns.
- That evening, Campbell and a friend observed H.C.’s burns and at least one blister.
- Campbell’s friend told Campbell she should take H.C. to the hospital, but Campbell did not do so because Campbell and Boyer planned to go to a bar that night.
- Later that night, after H.C. was in severe pain, Campbell took H.C. to the hospital, and authorities were notified.
- After investigation, Campbell was arrested and charged with felony child endangerment based on (1) failing to protect H.C. from abuse and (2) failing to obtain prompt medical care for H.C.’s burns.
- At trial, evidence included Boyer’s admission that he had physically abused Campbell for years.
- A jury convicted Campbell of felony child endangerment, and Campbell appealed.

## Issues

1. Whether the evidence was sufficient to prove Campbell “knowingly” permitted H.C. to be placed in a situation that endangered H.C.’s life or health by leaving H.C. with Boyer despite Boyer’s history of seriously injuring H.C.
2. Whether the evidence was sufficient to prove Campbell “knowingly” endangered H.C.’s health by delaying medical treatment after seeing serious burns and being urged to seek immediate care.
3. Whether Wyoming’s child-endangerment statute was unconstitutionally vague as applied to Campbell’s conduct.

## Decision

- The court affirmed Campbell’s felony child endangerment conviction.
- The court held the evidence supported a finding that Campbell acted “knowingly,” given her awareness of Boyer’s prior serious abuse of H.C. and her decision to leave H.C. in Boyer’s care.
- The court held the evidence also supported a finding that Campbell knowingly failed to provide adequate medical care by delaying treatment despite visible severe burns, blistering, and her friend’s advice to take H.C. to the hospital.
- The court rejected Campbell’s vagueness challenge, concluding the statute gave fair notice that leaving a child with a known abuser and delaying treatment for obvious severe burns fall within prohibited conduct.

## Legal Principles

- On a sufficiency-of-the-evidence challenge, an appellate court asks whether the evidence, viewed in the light most favorable to the verdict, permits a rational factfinder to find the elements of the offense beyond a reasonable doubt.
- A “knowing” mental state may be shown by circumstantial evidence, including a defendant’s prior awareness of a serious risk and decisions made despite that risk.
- A parent’s awareness that a caregiver previously inflicted serious harm on the same child can support a finding that the parent knowingly permitted the child to be placed in an endangering situation.
- A knowing failure to obtain needed medical care may be proven when serious injury is apparent to a reasonable caregiver and the caregiver nonetheless delays seeking treatment.
- A statute is not void for vagueness as applied when its terms give ordinary people fair notice of what is prohibited and provide standards sufficient to limit arbitrary enforcement; as-applied review focuses on the defendant’s conduct, not hypothetical cases.

## Conclusion

The court affirmed Campbell’s conviction for felony child endangerment because the evidence allowed the jury to find that Campbell knowingly endangered H.C. by leaving her with Boyer despite his prior serious abuse of the child and by delaying medical treatment for plainly severe burns, and because the child-endangerment statute provided adequate notice that such conduct was prohibited.


Campbell v. Wyoming, 999 P.2d 649 (2000)