Warcraft mom who let toddler die while she gamed gets 25 years; appeals court rules computer search lawful

Five years after her three year old daughter died from malnutrition and dehydration, a woman who played World of Warcraft obsessively every day is now in prison. Rebecca Colleen Christie of Las Cruces, NM has been sentenced to 25 years in prison, almost two years after her 2009 conviction on second-degree murder and child abandonment charges.

As Owen Good at Kotaku wrote:

The case against Christie showed that the day the girl died, Christie had been playing Warcraft and chatting with friends she'd made online for 15 hours. Prosecutors said there appeared to be so little food that the girl ate cat food.
In a ruling from the US Court of Appeals Tenth Circuit (PDF) this week, judges confirmed the right of the state to search computers for evidence. The ruling contains some extremely upsetting details about the life and death of Ms. Christie's toddler (referenced in the court documents as "BW"), but if you can make it past that, there are some interesting 4th Amendment considerations.

The ruling also references Christie's former husband, Derek Wulf, a man enlisted in the Air Force who was also an avid (or, one might argue, pathologically obsessive) gamer.

An excerpt:

Because BW died on an Air Force base, federal authorities bore the responsibility to investigate and the power to prosecute. They proceeded against Ms. Christie and Mr. Wulf separately. In our proceeding, a federal jury found Ms. Christie guilty of second-degree murder, two assimilated state law homicide charges, as well as an assimilated child abuse charge. After trial, the district court dismissed the two assimilated homicide charges and entered a twenty-five year sentence on the remaining second-degree federal murder and the assimilated child abuse charge.

It is this judgment both sides now appeal.

Much of the evidence presented at trial against Ms. Christie came from the computer she so prized. From their forensic analysis, FBI investigators learned that Ms. Christie's online activities usually kept her busy from noon to 3 a.m. with little pause. They learned that she was in a chat room only an hour before finding BW near death, and that she was back online soon afterwards. They learned from Ms. Christie's messages to other gamers that she was annoyed by her responsibilities as a mother and “want[ed] out of this house fast.” When Mr. Wulf was slated for deployment, she announced to online friends that she would soon be free to “effing party.”

Ms. Christie contends this evidence and more from her computer was uncovered in violation of her Fourth Amendment rights and the district court should have suppressed it from her trial. Because the court didn't, because it admitted the proof against her, Ms. Christie says a new trial is required. To be precise, Ms. Christie doesn't question whether the government's seizure of the computer satisfied the Fourth Amendment. The government took possession of the computer in May 2006 with Mr. Wulf's consent. Everyone accepts that he was at least a co-owner of the computer—it was a gift from his father—and everyone accepts he had at least apparent authority to relinquish its control. Instead, Ms. Christie attacks the propriety of the two searches the government undertook once it had control of the computer. To justify its searches the government does not seek to rely on Mr. Wulf's consent but points to a pair of warrants it sought and received, one for each search. It is these warrants Ms. Christie challenges, arguing they were issued in defiance of the Fourth Amendment.

The judges conclude by stating:
So it is we decline to reverse the district court on this score, just as we find no other reversible error anywhere else in its careful treatment of this sad case. The judgment is affirmed.


  1. Surely this counts as genuine psychological addiction? Couldn’t they do anything with that?

    1. “Couldn’t they do anything with that?” 
      Why would/should they? Yes it’s addiction, but Christie killed her child through neglect. Wulf contributed to this killing. If the case is as charged, why should I be hoping they escape charges, addiction or not?

      If there are true issues about how the evidence was gathered, that is different as far as the legalities are concerned.  The killers’ addictions, don’t factor in.

      1.  Well, quite. I’ve been addicted to things. Many times. It’s fucking hard, horrible and evil. It wouldn’t lessen my culpability though.

        1. You know, honestly, as a child of a severe addict… I don’t know what good it would do. What does culpability really mean. I’m being totally honest. Say you want punishment. Well ok, my parent was locked up a few times. Put through rehab. Hey, maybe if they fucked up enough they’d have been put to death. So… so what? What good is any of that? It doesn’t fix anything.

          To me, the question is why was this child still in her care? This is not the kind of thing that happens suddenly with no one noticing any signs.

          1. You are alive. I presume you are older than 3.

            Your addict parent(s) may have had their problems but you lived until an age where you could fend for yourself so there is no comparison.

          2. Not at all. I’m alive because some one intervened. :)

            The comparison is close to home. Though it doesn’t bother me much. I know perfectly well that I am lucky.

          3.  Life is not as simple as what you may first perceive.  Before declaring “there is no comparison”, it might be useful to learn more, and compare.

          4.  @Diogenes:disqus

            Let’s compare, shall we?
            Olive: Alive, Mature, Someone intervened, Addict parent.

            BW: Dead, Robbod of a chance to grow up, No one intervened, Addict parent.

      2. If it’s a genuine, uncontrollable psychological issue, then perhaps she should be put away in a secure psychiatric ward instead of a prison. I’m neither a lawyer nor a psychologist, so I’m not qualified to judge, but it is worth considering. I don’t think anyone is saying she should go free, certainly.

        1. Even if the motive is not punitive, we as a society need to protect society by locking up people who neglect children to death, regardless of why they did so. 

          1. Sure. As I said, the choice here should be between “sent to prison” and “involuntarily committed”, not “sent to prison” and “set free”.

  2. NOTE: Story is over two years old.

    BUT: How utterly sad. I’ve known people who obsessed over games, but the worst outcome was flunking out of college.


    1. The story is about the ruling which if you take the time to the read story and look at the ruling is dated yesterday.

  3. What’s most sad is this woman does not seem in anyway remorseful; instead she’s scratching and clawing her legal way to freedom.  Just go rot in prison for 25 years and maybe her conscience will kick in.

    Wow. Just wow.

    (wait for it…)

    1. actually, from the article:

      “At a sentencing hearing in mid-May, Christie didn’t ask U.S. District Judge Robert Brack for mercy, instead sobbing and telling him in between tears how sorry she was.
      “I’ll never get to see her grown up … That weighs on my heart. That was my little girl,” Christie said slowly, with difficulty, her shoulders hunched, the chains on her wrists shaking. She went on: “Not seeing what she needed, I’ll live with that for eternity. There’s nothing more that I want than to have her back with me, but I can’t have her back, and even now, I can’t talk to my older daughter. It was my responsibility to take care of her and I failed her and I’m sorry.”

      1. Psychopaths can be very convincing, but as far as I’m concerned her remorse or lack of it is irrelevant.  No sympathy for her ‘addiction’ either.  She let her three-year-old child die frightened, in terrible pain, and alone.  If it were within my power, I’d shoot her between the eyes myself. 

        1.  I wouldnt let her off that easy,  bullet is WAY to easy for her.    chain her to a tree  and refuse to feed her,  let her suffer the same death she inflicted   better yet,  film it and put it on prime time.  let people see  the results (yeah, i know.. i’m a bit bloody minded about stupid people getting away with killing someone at times) 

        2. That’s a fairly brisk process leading to execution there; your moral outrage pulling the trigger. Perhaps you’d prefer a little more consideration than that if the boot was on the other foot…

          How much time have you spent wondering where free will is supposed to come from? Informed by how much science?

          I’m pretty sure that once you’ve spent a while on the problem, you’ll develop a new appreciation for the idiom, ‘no man is an island’.

          A more informed perspective sees the futility of laying blame at the feet of individuals post facto, and with due respect for (universal, pervasive, inescapable) cause and effect, one seeks to beneficially alter systems; communities; contexts.

          1.  Yes, but her community has now reacted and restricted her access to other people to limit her weak sense of duty and obligation from again interfering with the appropriate functioning of society.

            In 25 years she will be infertile, and most likely of an age and with enough stigma that she won’t be able to cause the level of harm that she is capable of now. 

          2. Anyone claiming ends never justify means is unthinkingly parroting a nice-sounding soundbite they almost certainly don’t even agree with.

            Unless we’d prefer to erase all knowledge obtained by cruel means? Pff.

            No ethical framework can claim to be more humane than utilitarianism.

      2.  Maybe she’s so remorseful she’s suicidal, but the verdict is in response to the crime, not her remorse. Hindsight is 20/20 and remorse is ten-fold when one is facing punishment for one’s offenses.

        She deserves to do time and she deserves to be made an example of. This sort of neglect should not be tolerated.

        Her 4th amendment arguments may be valid, but sound incredibly weak to my layman ears. The lengthy contention about the length of time the authorities had her computer is moot: it’s evidence, and they can keep it as needed to conduct the case. Evidence is evidence. The other contention that the second warrant was invalidated by the terms of the first seems equally questionable, as a warrant in and of itself constitute a break against future searches. But whatever.

        1. “She deserves to do time and she deserves to be made an example of. This sort of neglect should not be tolerated.”

          I really hate to  break it to you, but people who do these kinds of things are pretty much by default incapable of learning by example. People who are capable of learning by example tend to notice such things as the effects of the other two years of neglect on their kid. The first time the kid started eating out of the pet food bowl might have been a good tip off, for instance.

          What is worse, is that people who are probably more like this will only feel sorrier for themselves really.

          The best you can hope for is to get *other* people to pay more attention to what is going on around them. If you’re an obsessive single person without a job who is online playing a game more often than not, and you notice some one who is the sole caretaker of a child is on there as much or more, talking about it in a cavalier way… report them. Even if the details you have on them are kind of sketchy. Do your best. Report them over and over again if you have to (you will probably have to). CPS are idiots generally, but it’s at least a shot for the child. Also I’m pretty sure if her online activity had been reported by some one else online then the 4th amendment wouldn’t matter anyway.

          I tend to think focus on punishment has the opposite effect. It’s more to protect everyone from having to deal with it. Flog one horrible parent, and we can pretend there aren’t 100 others, or that it will change them somehow. But feeling a sense of ease about putting one neglectful parent behind bars is actually a sort of tolerance in my mind of the just-lower-enough level of abuse and neglect going on all around us.

          1. I tend to agree, but you realize the people who would have heard this stuff would have no way of knowing who she was or where she lived, such as to report her by. Kicking her from the guild might have gotten her attention. I say, might. (Ugh.)

          2. Yeah, a long shot, though actually banning her might actually have helped. I’ll share your visceral shudder there.

        2. I don’t even see grounds for a 4th Amendment case. Fifty years ago, if you were in the pokey for a crime that you were officially charged with, it was probable cause for search and seizure of all your personal property. I have yet to see anything that differentiates your electronic or internet activity from your personal property, “it’s new” notwithstanding.

          A warrant is probably above and beyond what is even required.

      3. Of course she’s sorry! But she’s sorry her life is all effed up. I don’t see any evidence she’s sorry she killed her daughter. But then I got my degree in psych in 1981. Maybe things have changed…

    2. No… she’ll likely just be miserable. She was probably miserable before, so it probably won’t change much. Whatever her conscience is, it is probably so different from yours that it’s pretty much impossible to relate. TBH if I had to guess at least now she has a *reason* to be miserable and hate herself. Doubt she will be very popular among the other prisoners either.

      So it’s almost a win win.

      Except for the kid.

  4. So the story here is the Women had her computer searched and the Judge allowed it. Is that what we’re supposed to be outraged about?

  5. Sometimes I can imagine how people do horrible things by mentally amplifying some of my own shortcomings. Horrifying as the idea may be, I can at least imagine how someone deep in the throes of a crippling psychological addiction could lose track of time long enough to neglect a newborn for hours and hours on end, especially if the child was in a crib in another part of the home.

    But this kid was three. She must have been vocally pleading for food and water for days before she died. I can’t even begin to imagine what goes on in the brain of a parent who could let that happen.

    1. Let me help. Your shortcomings most likely aren’t that bad!

      Actually if the home was abusive enough and the kid was passive, she probably had adjusted to neglect and *didn’t* bother pleading with the parent. Especially if she was hurt or punished in the past for doing so. IOW, she likely learned to be complicit in her own murder. 

      That’s child abuse for you.

      1.  Yes, this is exactly the problem with “normal” people putting themselves in a victim’s shoes: if you haven’t been walking in those shoes your whole life, you won’t have the same reactions.  No matter how hard you try, you can’t possibly know.

  6. The court’s reasoning in rejecting her objections seems pretty sound to me, I find it very difficult to see anything but a last-ditch attempt to object to anything that may stick.

  7. Ironically anyone that could spend that much time playing WOW probably wouldn’t bat an eye doing prison labor (assuming it’s not hard manual labor).  Stamping out license plates all day can’t be any worse than grinding for quests.

    1. Somehow the terafllops and billions of triangles per second seem to make mindless tedium fun.

      Somebody wrote a book a year or two ago about game-ifying everything so, like, you get 50,000 points for taking out the garbage and stuff.

      Ersatz it may be, as far as utopian visions go, but it’s a damn sight more achievable than most.

  8. Letting a toddler die deserves 25 years, or anything the system is empowered to throw at it.

    I still play WoW and  I don’t plan on quitting. I have cats, not a toddler. And yet, if the cats need something I am AFK. Period.

    Failing at life is a thing. WoW is merely an excuse.

  9. If you let a kid who relies on you for everything to die because you’re playing a video game: fuck you, fuck your 4th amendment rights and fuck your attempts at manipulation of the legal system to get a lesser sentence.

    I don’t even give a shit about reform… this is brutal punishment for brutal neglect. This selfish asshole cut a little girl’s life short by 74 years (according to average life expectancy) so 25 years seems a perfectly reasonable sentence.

    1. They should “forget” to give her any food or water while she rots in prison.  What a horrible way to die…ugh, this story has made me extremely sad and angry at the same time.

  10. I have not read the ruling (not sure I can handle the details of what exactly happened to the little girl), but the first excerpt mentions that the girl probably ate cat food because she was so hungry.

    So … the woman remembered to feed the cat, but not her daughter.  Really?!

    1.  You can leave out big piles of food for cats; it’s common to use a gravity-fed feeder. It’s not always good for the cats and they eat too much, but you can do it. So she didn’t necessarily take time for the cats, either.

      1. You know, those gravity-fed feeders could be used for dry cereal too.  She could have actually taken better care of the child if she’d just gotten another feeder.

        If the child had only lived another couple of years, she could have taken over taking care of herself.  It wouldn’t have been a great childhood, but between eating at friends’ houses and stealing food from the local store she could have made it.

  11. I’d like to hear more about why these are fourth amendment right issues. Did I miss something above?

    For one thing, even if the husband hadn’t consented to the seizure of the computer, it sounds like the government could have gotten a warrant for it, seeing as they got warrants for searching it after.

    If this case’s fourth amendment interests only rest upon her challenge of the detailed terms of the warrants and how the searches were conducted, and if you, the knowledgeable reporter, don’t see good ground beneath that challenge, then why should we be interested in that part of the story?

  12. I get freaked out if my kid doesn’t poop at the same time every day, how the fuck do you not notice that your kid doesn’t have anything to eat or drink for several days?  Are you not feeding yourself?  What about this older daughter?  Why didn’t she try to help the younger one?  OliveGreenapple might be right about a wider pattern of abuse.

    I really need to go watch kitten videos now.  Maybe some otters and pandas, too.  

  13. To me a dead infant seems to establish probable cause to search the computer.

    Addiction is generally not used in the same way a plea of insanity is. Addiction may mitigate sentencing, but it won’t acquit you of the charge.

  14. She deserved a much longer sentence than that.  I cannot imagine the suffering that innocent little child went through.   I hope the mom rots in hell.

  15. This makes me feel dirty playing video games. Extremely sad story. Hope she rots.

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