## Facts

- Martha L. Woods was a foster and adoptive parent prosecuted in federal court for crimes against infants and young children placed in her care.
- The primary allegation involved the death of eight-month-old Paul David Woods, a pre-adoptive foster child living in Woods’s home.
- Before entering Woods’s care, Paul was described as a normal, healthy infant without breathing problems or cyanosis.
- After placement with Woods, Paul suffered repeated episodes of respiratory distress and cyanosis while in Woods’s exclusive custody, and he ultimately died in her home.
- The government contended the death was consistent with suffocation rather than natural causes, and relied substantially on circumstantial and medical evidence.
- The prosecution also introduced evidence concerning injuries and deaths involving nine other children previously in Woods’s household to show a repeated pattern of similar incidents and to negate accident or natural causes.

## Issues

1. Whether the evidence was sufficient to prove the corpus delicti of murder, including that Paul’s death resulted from a criminal agency.
2. Whether evidence of injuries and deaths involving other children in Woods’s care was admissible for non-propensity purposes, including to prove corpus delicti and Woods’s responsibility.
3. Whether the trial court’s limiting instructions on the permissible use of the other-acts evidence were legally adequate.
4. Whether the district court committed reversible sentencing error by not sentencing Woods under 18 U.S.C. § 4208(a) on the first-degree murder count.

## Decision

- The Fourth Circuit affirmed Woods’s convictions and sentences.
- The court held the government’s proof—medical evidence, circumstantial evidence, and the pattern evidence—was sufficient to establish the corpus delicti and allow the jury to find criminal agency beyond a reasonable doubt.
- The court upheld admission of the evidence concerning other children, concluding it served legitimate purposes (including absence of accident and proof of criminal agency) and that its probative value outweighed unfair prejudice in this type of prosecution.
- The court rejected the argument that each prior incident had to be proved with a heightened level of certainty before admission; the incidents could be considered collectively to show a pattern.
- The court found no reversible error in the jury instructions limiting the use of other-acts evidence.
- The court found no reversible error related to the requested sentencing alternative under § 4208(a), and left the life sentence for first-degree murder undisturbed.

## Legal Principles

- The corpus delicti of murder may be proved by circumstantial and medical evidence, and in infant-suffocation prosecutions a pattern of repeated similar incidents may be highly probative where direct evidence is scarce.
- Evidence of other crimes, wrongs, or acts is inadmissible to prove propensity, but may be admitted for other relevant purposes, including intent, plan, identity, and absence of mistake or accident, subject to balancing probative value against unfair prejudice.
- In assessing other-acts evidence offered to show a pattern in child-abuse prosecutions, a court may consider the incidents collectively when determining probative force and admissibility.
- Limiting instructions are required to restrict the jury’s use of other-acts evidence to permissible purposes and to reduce the risk of conviction based on character reasoning.
- Appellate review of sentencing claims will not result in relief absent a legal error that renders the sentence unauthorized or otherwise reversible.

## Conclusion

The Fourth Circuit affirmed Woods’s first-degree murder and related convictions, holding that the government sufficiently proved criminal agency through combined medical, circumstantial, and pattern evidence, and that evidence of similar injuries and deaths involving other children in Woods’s care was properly admitted for non-propensity purposes with adequate limiting instructions, with no reversible sentencing error shown.


United States v. Woods, 484 F.2d 127 (4th Cir. 1973)