Cledir Mendes Barros withdrew his young daughter, S.B., from her Gwinnett County elementary school after teachers reported her repeated injuries to child-welfare officials, telling a teacher that the child was possessed by demons and would be home-schooled by his wife. About two months later, while Barros was working as a truck driver, his wife called to say she had killed the child, and an autopsy showed that S.B. had been beaten with a rolling pin until she bled internally. Barros was convicted of second-degree cruelty to children on the theory that he criminally negligently left the child in the care of a person he knew to be abusive. The Court of Appeals of Georgia found the evidence sufficient, pointing to the child’s visible injuries, the family-services investigation, and Barros’s admission that he had seen his wife strike the child. The court held, however, that the trial court committed reversible error by refusing Barros’s written request to charge the jury on reckless conduct as a lesser included offense. Relying on Shah v. State, the court reasoned that Barros’s testimony that he knew of only one incident and then forbade corporal punishment was some evidence from which a jury could find a conscious disregard of a substantial risk rather than second-degree child cruelty. Because the conviction was reversed on that ground, the court did not reach his ineffective-assistance claim.