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Ratledge v. State

The trial court should have merged defendant's convictions for cruelty to children because both counts were based on his act of immersing the 2-year-old victim's feet in excessively hot water.

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Joseph Ratledge appeals from his convictions on two counts of cruelty to children. He contends that i the evidence was insufficient to sustain his conviction, ii the trial court erred by admitting evidence of prior difficulties between himself and the victim, and iii the trial court erred by failing to merge the two counts against him for sentencing purposes. We hold that the evidence was sufficient to sustain the convictions and that the trial court properly admitted the evidence of prior difficulties, but since the trial court erred by failing to merge counts one and two, we must vacate the sentences on both counts and remand the case for resentencing.

Viewed in the light most favorable to the verdict, the evidence reveals that while caring for two-year-old H.M., Ratledge took the child into the bathroom and immersed her feet in scalding hot water, causing H.M.’s skin to burn off. H.M. suffered painful burns, screamed in pain, and had nightmares during her recovery. H.M. told others that Ratledge was the one who burned her by holding her feet down in hot water.

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