93 N.Y.2d 561 (1999)
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A person who assumes the role of primary caretaker of a child, even temporarily, can be considered “legally charged” with the care of that child under New York Penal Law § 260.10(2), making them liable for endangering the welfare of the child.
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Summary
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The case concerns the death of three-year-old Shanaya Jones, who was fatally beaten by her father while in the care of her stepmother, Carroll. Carroll was indicted for endangering the welfare of a child under Penal Law § 260.10(2). The key issue was whether Carroll was “legally charged” with Shanaya’s care. The Court of Appeals held that the Grand Jury had sufficient evidence to indict Carroll, as she acted as the functional equivalent of Shanaya’s parent during the child’s extended visits, thus establishing a legal duty of care. This duty extended to protecting the child from abuse, even from the biological parent.
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Facts
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Shanaya Jones, a three-year-old, visited her father and stepmother (Carroll) for an extended period.r
Carroll identified herself as Shanaya’s “mother,” “stepmother,” and “primary caretaker” during these visits.r
Shanaya’s father physically abused her over several days, which Carroll witnessed.r
Carroll did not seek medical attention for Shanaya until it was too late, and Shanaya died from her injuries.r
An autopsy revealed extensive injuries, indicating prolonged abuse and neglect.r
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Procedural History
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Carroll was indicted for endangering the welfare of a child (Penal Law § 260.10(2)).r
The Supreme Court dismissed the indictment, finding insufficient evidence that Carroll was “legally charged” with Shanaya’s care.r
The Appellate Division reversed, concluding that Carroll was “legally responsible” under Family Court Act § 1012(g) and stood in loco parentis.r
The Court of Appeals affirmed the Appellate Division’s reversal, focusing on the “legally responsible” standard under the Family Court Act.r
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Issue(s)
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Whether the Grand Jury had sufficient evidence to indict Carroll for endangering the welfare of a child under Penal Law § 260.10(2), specifically, whether she was “legally charged” with the care of Shanaya Jones.
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Holding
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Yes, because the evidence presented to the Grand Jury established a prima facie case that Carroll was legally responsible for Shanaya’s care under Family Court Act § 1012(g), and therefore legally charged with Shanaya’s care under Penal Law § 260.10(2).
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Court’s Reasoning
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The Court reasoned that Penal Law § 260.10(2) does not define “person legally charged with the care or custody of a child,” thus the Court must define it, considering the statutory language, legislative purpose, and the Penal Law’s directive to construe its provisions fairly to promote justice. The Court referenced the Family Court Act § 1012(g), which defines