Delaware Supreme Court overturns conviction in fatal Howard High School bathroom attack

The Delaware Supreme Court has overturned the criminally negligent homicide conviction of a teen in the beating of Amy Inita Joyner-Francis at a Wilmington high school in April 2016.

Trinity Carr was 17 when a Family Court judge found her guilty of criminally negligent homicide and third-degree criminal conspiracy last year. The conspiracy conviction stands; it was not appealed.

Joyner-Francis was 16 when she died on April 21, 2016, after a violent encounter with Carr and two others in a restroom at Howard High School of Technology.

The state medical examiner testified that Joyner-Francis suffered sudden cardiac death brought on by a rare combination of heart and lung defects that contributed to her death.

In its ruling release Thursday, the state Supreme Court ruled that Carr could not have foreseen that the attack would cause Joyner-Francis to die from cardiac arrest.

"No reasonable factfinder could conclude that (Carr's) attack – which inflicted only minor physical injuries – posed a risk of death so great that Tracy was grossly deviant for not recognizing it," the Supreme Court opinion reads.

The court opinion addresses Carr and Joyner-Francis by pseudonyms. Trinity Carr is referred to as Tracy Cannon, and Joyner-Francis is called Alcee Johnson-Franklin.

“Department of Justice prosecutors are disappointed but respect the court’s decision,” said Carl Kanefsky, an agency spokesman.

During a bench trial, prosecutors accused Carr, Zion Snow and Chakiera Wright of planning the confrontation in the 20 hours before the attack. Snow was found delinquent of third-degree conspiracy.

Wright was found not delinquent after Family Court Judge Robert B. Coonin said there was insufficient evidence to show she participated in the plan.

At the center of the prosecution's case was cellphone video of the April 21, 2016, assault. The video shows Carr dragging Joyner-Francis by her long, braided hair through a handicap-accessible stall in the bathroom. Carr swings her arms and lands punches onto the head and torso of Joyner-Francis, who was on the floor clutching her purse.

The fight exacerbated a pre-existing heart condition in Joyner-Francis, leading to her death, according to testimony from the state Medical Examiner's Office.

During the trial, attorneys argued questions such as what a “reasonable” person should expect as a result of a fight, what type of clothing is worn by kids preparing to fight and whether Joyner-Francis was a participant in the fight.

Coonin, in his ruling, said high school students should know that a fight could result in serious injury. Carr's failure to perceive the risk assumed in the attack constituted a "gross deviation" from the standard of conduct of her peers, he said.

"The attack ... posed a risk of potential catastrophic physical harm including death by virtue of the tile floor, walls and fixtures," Coonin said. "Had a death resulted from internal bleeding after striking her head on the floor, would that result in any way change the risk that the assault itself created?"

Furthermore, the evidence presented during the trial – including threatening messages posted by Snow on social media saying, "We gonna get her" – demonstrated Carr and Snow were planning to attack Joyner-Francis, Coonin said.

The judge found Carr delinquent – a term used when a juvenile is found guilty – of criminally negligent homicide and third-degree conspiracy.

In order to be liable for criminally negligent homicide, the Supreme Court opinion stated that the courts had to prove that Carr both acted with "criminal negligence" and "caused" Joyner-Francis' death.

The Supreme Court found that Carr's actions did not meet the legal standard for criminal negligence because no reasonable person could conclude that the attack posed a risk of death so obvious that it would be a "gross deviation" for Carr not to see the potential outcome.

"(The attack) – reprehensible as it was – was not so violent that it presented a readily apparent risk of death," the opinion states.

Given the rare heart condition, the Supreme Court opinion states it is not enough for criminal culpability that Carr's actions happened to set in motion a chain of events that led to the victim's death.

The ruling is unlikely to have much impact on Carr's sentence. In June, Carr was sentenced on the homicide and conspiracy charge to six months at Grace Cottage – a secure residential program for female youth near Wilmington.

The conspiracy conviction will stand, but Thursday's Supreme Court order directs the Family Court to resentence Carr based only on that offense.

THE DEATH OF AMY JOYNER-FRANCIS:

Six-month sentence for defendant in Joyner-Francis' death

Delaware reacts to the Trinity Carr ruling

Joyner verdict shows 'consequences' of actions

Expert: Joyner-Francis heart condition extremely rare

Trinity Carr to be tried as juvenile for fatal fight

Witness: Only 3 punches landed directly in Howard fight

Wilmington school death: Unforeseeable or planned attack?