State v. Williams, 4 Wash.App. 908 (1971) p472.
Subject:
involuntary manslaughter
Facts:
Husband and wife, both in their early twenties are Native Americans, neither of which had very much formal education. Their child developed a toothache which turned into an abscessed tooth which developed an infection and eventually became gangrenous. This caused an inability to eat, which lowered the child's immune system, cause him to eventually die from pneumonia. Defendants were afraid of taking their child to a doctor for fear of having him taken away from them.
Procedure:
Found guilty of manslaughter and sentences were imposed on both husband and wife.
Issue:
Should D be found guilty of manslaughter for negligently failing to supply their 17 month old child with necessary medical condition, as a result of which he died?
Rule:
When one causes death through lack of ordinary and reasonable care of a man of reasonable prudence, he can be held to manslaughter.
Holding:
There is simple or ordinary negligence in this case, which is sufficient to support a conviction of statutory manslaughter.
Rationale:
Defendants were sufficiently put on notice regarding their baby's health. The lack of improvement in the baby's condition was enough to require them to obtain medical care for the child.
Policy/Notes: