Daniel Scruggs hanged himself in the closet where he slept at the age of 12 in 2002. His mother, Judith Scruggs, was convicted in 2004 of keeping the home in Meriden, Conn., that she shared with her two children in such a condition that it endangered Daniel's mental health.
The Supreme Court, in a unanimous decision, found that the prosecution could show no objective standard on housekeeping. Justice William Sullivan pointed out that social service workers closed the family's file only a few days before Daniel's death.
"We do not suggest that the department's failure to take action constituted conclusive evidence that that the conditions in the apartment did not pose a risk of injury to the mental health of a child," Sullivan said. "It does constitute evidence, however, that the conditions in the apartment did not pose such an obvious risk that it would be within the knowledge of an ordinary person."