Although the defendant was successful on appeal in Jones, the case makes clear that the state may sometimes punish people for omissions. If a properly instructed jury had found that Jones had undertaken a duty to care for Anthony Lee Green, Jones would be deemed to have caused the death, even though her conduct was entirely passive. Would such a result violate the princi- ple of Proctor? Isn't it obvious that all citizens face potential criminal liability for such omissions as failure to file income tax returns? Sometimes, a statute is explicit that an omission to act can be punished, as with the tax evasion law or with the laws that make it a crime for certain covered professionals not to report signs of child abuse. So how does the Jones doctrine help courts to interpret legislative intent where statutes are not so explicit? What kinds of statutes