A mother who broke her child's arm by throwing the 23-month-old over a couch will avoid a jail sentence for the incident.
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Charges against the woman, now aged 21, were proven following a hearing in the Wodonga Magistrates Court over the December 2019 incident.
The court heard the mother had failed to seek medical help for three days and red flags were raised at the Wodonga hospital when the boy was taken for treatment.
Multiple bone breaks were found and X-ray images were tendered to the court.
The incident occurred in the early hours of December 22 but the child wasn't taken to hospital until Christmas Day.
The court heard the mother had been exhausted, anxious and stressed at the time of the offending.
"Love the kid but he's driving me crazy," she wrote in a message to her father.
Lawyer Anna Dixon said it wasn't a protracted incident.
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"It's clearly a mum who loves her son but is struggling," she said.
Police are not seeking a prison sentence in the matter, but prosecutor Penny Lawler said it was a serious offence.
"He's one of the most vulnerable members of our community," she said of the child.
"He's entitled to care and safety, and at that age places his entire care and trust in the people who are meant to look after him.
"The result of the offending had significant physical consequences for (the boy), and the potential for emotional and psychological harm could be significant."
While Leading Senior Constable Lawler said rehabilitation was important, "I don't think it's the be all and end all".
"In my submission there's nothing before the court that shows any remorse," she said.
The court heard the woman had grown up in extreme hardship and was just a child herself when she became a mother.
Magistrate Ian Watkins said he wasn't considering a jail term.
The court heard a community corrections order was within range and Ms Dixon said the woman's rehabilitation was already under way.
The woman will be sentenced later this month.
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