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NUPlBER: 18C05c:.l006-FA- (]7 FOR PROBABLE CAOSE Resulting


of a Dependent


35-46-'-1-4 (a) (.3)

The undersigned deposes McConniel has committed Death, a Class A Felony,

Class A Felony

and says upon information and belief that Ryan Neal the offense of Neglect of a Dependent Resulting in and in support thereof says as follows:

1. That this affiant is an investigator for the Muncie Police Department -assigned to the Smart Team and obtained all information herein while performing the duties as such. 2. On March 4, 2010 the affiant was contacted concerning the report of a five-year-old child who had been taken to Riley Hospital in Indianapolis from Muncie, Indiana. The child died on March 9, 2010 at Riley. The assessment from Dr. Antoinette Laskey was that this five year five month old female with hypernatremia (extremely high levels of salt), extreme malnutrition and evidence of physical trauma to nearly all body surfaces and no identifiable underlying medical cause for her condition. To a reasonable degree of medical certainty, the injuries and findings described cannot plausibly be explained by accidental injury, preexisting medical illness, reasonable discipline or benign events. Therefore, these injury should be considered consistent with inflicted trauma, that being child abuse. 3. The five-year-old child was L.M. date of birth October 3, 2004. L.M.'s natural father is Ryan Neal McConniel date of birth February 16, 1977. L.M.'s natural mother is Amber Huggins. L.M.'s stepmother is Britney McConniel date of birth October 20, 1985. 4. Prior to August 22, 2009 L.M. had been in natural mother Amber. All medical records indicate that prior to this date L.M. was physically and emotionally. Prior medical with Amber indicate her nutritional status development. L.M. had been seen by doctors have a weight of approximately 38.5 pounds noted. the care and control of her and reports and photographs happy and healthy, both records during L.M.'s care was normal along with normal in Tennessee and was found to with no behavioral issues

5. On August 22, 2009 L.M. was picked up by Ryan and Britney and taken into their care, custody, and control. L.M. was moved to Indiana and lived in several locations, the last reported as 2304 S. Ebright St., Muncie, IN. Included in the household was Ryan and Britney, L.M.'s natural sister K.M. age 9, stepbrother K.L. age 4 ~ and half-sister H.M. approximately 16 months. Also included in the household were grandparents Robert and Angie Lee and Aunt Samra Lee.

6. Per Brittany and Ryan, as reported in the Riley Hospital records, they reported L.M. 's behavior was odd from the time she first came to their home. They reported L.M. would talk little, she would climb the.wall like a wet cat if they tried to give her a shower. She would pee and p-GQ}? in he r p-ants 5G IHldGh that they sta±"te-a ptrt:tin~ he r inEli-ape~s:even though she had been potty trained for 3 years. She would store food in her cheeks. She would mutilate her dolls. L.M. started biting herself and her siblings. She would bite them badly and repeatedly. She would bite her own fingers and toes to the point ofcbleeding. She then began playing with her stool. She would get stool from her own diapers and put it on her siblings and laugh about this. L.M. would smear it in their hair and try to put it on her dad, They reported this is the only time L.M.would Lauqh ..Asked if. t.heyrs ouqht; medical attention related for this i3:1?rmingbehavj,.or:they·reP9'rted no. 7. The more time L.M. spent in the custody of Ryan and Brittany, the more her behaviors became increasingly bizarre. There were reports of rocking and staring at the wall for hours repeating I hate myself. She was reported to eat food out of trash cans. She would eat her own vomit. She would wander the house at night and not sleep. L.M. was losing weight due to no appetite. She even began to eat her own feces. She was reported to see little blue bunnies that kept her awake at night telling her to do bad things. This included stabbing daddy. L.M. was found with both a butcher knife and scissors during this time. Ryan and Brittney noted that they believed L.M. to be a victim of past physical or sexual abuse from Amber but yet did nothing to report this or to try to receive help. These reports of Amber abusing L.M. were not substantiated. 8. On November 19, 2009 L.M. was taken to St.Vincent Randolph Hospital in Winchester Indiana complaining of soap in her eyes. Attending physician was Dr. Tom Huntington. Ryan and Britney reported L.M. 's primary care doctor as Dr. Aaron Shoemaker in Winchester IN. As became apparent to this affiant throughout the investigation, including all medical records obtained through L.M. 's death at Riley Hospital, Ryan and Britney reported Dr. Shoemaker as the primary care physician throughout. However Dr. Shoemaker, although supposedly attending to L.M. 's malnutrition issues, never one time saw L.M .. Additionally neither Ryan nor Britney reported any emotional or behavioral problems to the medical providers at St. Vincent's that they had observed in L.M .. 9. On December 8, 2009 L.M. was taken to Ball Memorial Hospital ER and seen by Dr. Tom Mangelt. Presenting problem was noted as broken right fingers from jumping on a bed. Once again Dr. Shoemaker was listed as L.M.'s primary care physician. Follow-up with Dr. Shoemaker or Central Indiana orthopedics was ordered to occur w~thin three days. L.M. was never taken to any follow up care. Once again neither Ryan nor Britney reported to medical providers any of L.M.'s previously recognized bizarre behaviors. 10.On December 16, 2009 L.M. was seen by Youth Pastor Timothy Black outside the Southside Church of the Nazarene. Ryan asked Pastor Black if he would come outside to their van and see if he could convince L.M. to come inside the church for a party. Pastor Black said he went outside to the van and introduced himself to L.M .. Pastor Black asked L.M. if she would like to come inside with the other kids and have cookies and juice. He noted that from the start of his observation of L.M. she sat in the car seat and repeated over and over, "fucking bitchN• After about five minutes Pastor Black gave up and told Britney and Ryan that L.M. needed professional help and that they should seek help very soon. L.M. later came into the back of the church and stayed away from everyone

else and just stared colored and frail.

off. Pastor

Black noted

she seemed

very pale

11.L.M. was next seen by a medical provider on February.4, 2010 at Southway Urqerrt; Care by Bill Gos:nell Rt.(J. L. Lv1. S presentirlg- probie-ril was rio te d too be burning urination and Ryan stated that L.M. 's vaginal area did not look normal. When Gosnell tried to examine L~M. she began knocking herself in the head with her fist but not hard enough to cause bruising. Ryan reported that L.M. had been hitting herself hard enough to bruise herself and had regressed back to wearing diapers. None of L.M.'s other problems were reported. Ryan told Gosnell that L.M. had been with Amber the last 6 to 7 months and that they were not happy with L.M.'s care by her ".In truth,L.M. hadbeenihRyanand Britney's care for the last six months. Dr. Shoemake~ wasonceagaiI1notedtobe L.l1.'5 primary care . physician. Gosnell urged Ryan and Britney to gyt L.M. in to Meridian psychological services. .

12.0n February 10, 2010 L.M. was taken to Meridian services where she saw Karen Royer. The first session was with Ryan and Britney. They reported L.M. had lost 3 pounds in the last two months, defecated in her brother's bed while he was in it, hit herself, and would sit on the floor rocking for hours saying she hated herself. She was reported to have been hallucinating the last 2 to 3 months and would see blue bunnies that made her do bad things, eat out of the trash, make herself vomit and eat her vomit, smear and eat her feces and also use the phrase fucking bitch often. Britney and Ryan also said L.M. wasn't potty trained yet and still was wearing diapers. One and a half months ago L.M. hid a knife in her diaper and wanted to stab her stepmother Britney. Karen Royer met again with L.M., Ryan and Britney on February 22, 2010 wherein they reported that L.M. had hid scissors in her diaper to hurt Ryan. L.M. told Karen that she slept on a pallet on the floor at home because her bed was dirty from her wetting and defecating in the bed. L.M. referred to her natural mother as Amber and said Amber made her take cold showers, her clothes were dirty, he~ fingers would get bent back, and Amber would stick her fingers in her when she was bad. None of these behaviors as reported inflicted by Amber were confirmed. Karen Royer met with L.M. again on March 1, 2010 noting that L.M. was awake for only about 10 minutes. Britney said L.M. was hiding food in her diaper, eating vomit, and would wander the house and wouldn't sleep more than three hours. L.M.~looked exhausted, frail and fragile. Karen Royer encouraged them to get food in her. Britney reported that they were giving her Pediasure and Gerber Junior foods. Karen Royer reported that in all her years of dealing with kids she had never heard of such bizarre behavior and believed L.M. was being seriously sexually abused. Out of the three appointments L.M. was only seen briefly on two occasions. Dr. Shoemaker was once again reported as her primary care physician and was reported to be treating L.M. for her nutritional issues. 13.0n March 2, 2010, an ambulance was called for L.M. after she had fallen and hit her head earlier in the day. Other than reporting that L.M. would scream very loudly when not paid attention to, Ryan and Britney reported no other problems with L.M .. L.M. was given a CT scan at Ball Memorial which was normal. Clinical impression was noted as malnutrition and behavioral problems. Britney reported that she did not know if L.M. was really hurt or just acting out. L.M.'s parents reported that L.M. fell a lot, gets dizzy, walks into things, hits herself, and has not been eating over the last couple months. They reported that L.M. was seeing a psychiatrist at Meridian services and her pediatrician Dr. Shoemaker was aware of her conditions and she was being treated by Dr. Shoemaker who had weighed her two days earlier at 37.4 pounds. As noted

previously L.M. never saw Dr. Shoemaker. When asked about L.M. 's medical history Ryan and Britney reported no surgeries, broken bones or other medical problems.

lZl.Laf.er in the afternoon

oh March

2, 2010, L.M. 's

the extent that she was bumping into other people and appea.red unable to see. L.M. was becoming nonresponsive. Believing this to be a psychiatric issue, Ryan and Britney tried to contact Meridian services and when unable ', took L. M .to Valley Vista hea.lt-h system in''Greenwood India.na . L.M. was seen by Ellen Harrington, LMHC. Britney and Ryan reported some of L.M.'s prior behavioral issues including seeing blue bunnies for six months along with a four pound weight loss in the last two weeks. They noted that L.M. 's bizarre behavior hadincreased,t0c:iay,that being March 2, .2010 . Dr. Shoemaker was repo:r:tE:dsL, .M.'s prj_If\p-p:iCiHephysicia.Tl. a when requested to sign a release Of information to Dr.,>Shoerrtaker, Ryan and Brittany provided an invalid telephone number and address in Winchester. L.M.'s diagnosis was lack of supervision, failure to thrive, malnutrition, and medical neglect. L.M. was referred to Riley Children's Hospital in Indianapolis, Indiana. 15.L.M. presented to Riley Hospital in the early-morning hours of March 3, 2010 where she was seen by a multitude of medical providers L.M.'s primary physician at Riley was Dr. Antoinette Laskey who is a child abuse specialist for Riley Hospital and the head of the Indiana State Child Fatality Review Board. Shortly after arriving, L.M. developed generalized tonic colonic seizure, respiratory failure and shock. She was found to be suffering from severe malnutrition with no subcutaneous fat or fat reserves whatsoever. It was reported that L.M. had a very significant psychiatric history since returning to father's custody in August of 2009. This history included aggression, feeding dysfunction, self mutilation, hallucinations, hiding knives and threatening to kill family members, eating feces and her own vomit. Most significantly L.M. was found to be hypernatremic upon admission which is an extremely high sodium level or salt in the blood. In this case her level was 187. Anything over 152 is likely to cause seizure and death. Ryan and Britney now admit to Riley Hospital Representative that Dr. Shoemaker has never seen L.M .. They report that L.M. was seen by Meridian services for the last five weeks one time per week. 16.In a psychological evaluation done at Riley Hospital Ryan and Britney reported that soon after returning to their custody that L.M. 's behavior was as follows; talked little, climbed the wall like a wet cat if tried to shower, pee and poop so much that she needed diapers, store food in her cheeks, mutilate toys, biting self and siblings, bite her own fingers and toes to the point of bleeding, play with and smear poop on her siblings and Ryan which was the only time that L.M. would laugh. Additionally reported was hiding scissors in diapers to stab dad, hiding a butcher knife to stab Britney, choking herself and playing with her genitals and inserting items into her vagina. Ryan and Britney admitted that they sought no medical or psychological attention for these behaviors at the time. The psychological evaluation summarized that based on the history provided by father and stepmother, symptoms reported and observed over past six months are concerning for severe and persistent abuse and neglect. The patient's severe malnutrition is concerning, especially in light of the fact that no medical treatment was sought until the last month. Behavioral symptoms as severe and progressive as those reported by father and stepmother would've also warranted earlier evaluation by physician and mental-health professionals.

condition worsened to

17.Dr. Laskey's final reports note that she had reviewed L.M.'s chart in its entirety including all labs and radiological studies done to date. She notes that father and stepmother never saw L.M. eat salt and that no salt shakers were reported. Later salt shakers were reported but kept at a height. Finally it was admitted that thefarnily salt shaker was a Ragu jar with holes punched in the lid. Dr. Laskey reports that external administration of salt is indicated and that a child could not eat the quantity of salt voluntarily that would cause the deadly levels presented. Further, -Dr.Laskeyreports~ that ·L,M:had bruisesy,scrapes, and abrasions over multiple body surfaces. Also multiple blood blisters on fingers into nails on feet and that the fing~rs appeared chewed off. Further that L.M. was malnourished to the· point. of wasting. She was the .' averagesizeof a 30 month old child withno fat stores atall ..TQieach tl;1isSPQditionwould take some time if she startedre:Lativelyno:(I1l~J~:It is not cleai:,-why no care was sought in .theface of extreme·bi:z;cir;c.e •.. behavlorsin a child who was reportedly normal developmentally especially as symptoms worsened over time. Despite all efforts to identify an underlying medical cause for life-threatening condition, there is absolutely no evidence that this is an intrinsic medical condition. Given her overall physical condition including extreme malnutrition, the injuries noted on nearly all body surfaces and her extreme lab derangements, these findings are most consistent with physical abuse as evidenced by her physical injuries and most likely administration of some form of salt, possibly as punishment. It is highly likely there is a component of extreme psychological and emotional abuse. Dr. Laskey reports "there is clearly medical evidence of extreme medical neglect. Her declining weight, ultimately putting her at the average weight of a 2 1/2 year old child, her extreme psychiatric symptoms with no attempt to seek medical care for them and her eating problems all would have been more than obvious to a reasonable caregiver as necessitating emergent medical care." Laskey further states that "review of the medical literature and discussion with various consulting services indicates that salt administration would likely result in a rapid increase in her sodium levels, this could not have been a longstanding condition, i.e. days." Dr. Laskey ended her report noting that "to a reasonable degree of medical certainty, the injuries and findings described above cannot plausibly be explained by accidental injury, preexisting medical illness, reasonable discipline or benign events. Therefore, these injuries should be considered consistent with inflicted trauma that being child abuse." 18.In a follow-up interview with Amber, L.M.'s natural mother, Amber noted that in August 2009 L.M. was healthy and gaining weight appropriately. L.M. did not exhibit any signs of psychosis or altered mental status. She exhibited no staring spells, hallucinations or being unresponsive. L.M. was extremely outgoing and playful with other siblings showing no signs of aggression or behavioral concerns. Lastly, that there were no self injurious behaviors as noted after being returned to Ryan and Britney's. Ryan admits in an interview on March 10, 2010 that when he got L.M. in August 2009 from Amber that L.M. looked happy and healthy. Further that he has seen a very big decline in L.M. and her health in the last five or six months and that he shouldn't have gotten her from her natural mother. Other witnesses indicate that Britney would withhold food from L.M. as punishment. 19.In a psychological evaluation performed on K.M. on May 13, 2010 it was determined that she is of average cognitive and academic skills and was able to demonstrate that she understood right from wrong and true statements from false statements. In the evaluation K.M. noted that L.M. got in trouble when she was bad and that Britney and Ryan

"would hit her on the bottom of her feet with a stick from a gate and make her do jumping jacks, push-ups and stuff." She went on to say that "it was scary there I didn't like the way they hit her it made me cry." It was also reported that K.M. will not eat food that she cannot witness being cooked and has asked what would happen if someone put poison in food. K.M. also indicated that she had experienced a history of severe Pllysical pun.i shmerrt, Itvv21salso repo;ctedbyI):.M. that wheT). ba.dL .. M:.was made to hold heavy cans of food or heavy books with arms outstretched and was hit with a wet towel. Lastly, she reports that no one gaveL.M. hugs or kisses. 20.Thatthis affiant; isi!=9:1:lesi::ingthat this Court. issue "awarrapt'£Q;cthe arrest of Ryan)\Jeal McCorrnielfor the offense of Negle¢:tof DependeIlt Resulting in Death, a . Class A FeloIly. I affirm under the penalties of perjury that the true to the best of my knowledge and belief. Date: foregoing representations are




L. Arnold

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