California, United States of America
The following excerpt is from People v. Owens, A152779 (Cal. App. 2018):
3. The court distinguished between those who directly abuse a child and those who do so indirectly, such as by failing to seek medical treatment, or permitting situations that put a child in danger. (People v. Sargent (1999) 19 Cal.4th 1206, 1218-1219 (Sargent).)
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