State v. Williams
484 P.2d 1167 (1971)
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Rule of Law:
A parent or guardian has a legal duty to provide necessary medical care for a dependent child, and a breach of this duty based on simple or ordinary negligence is sufficient to support a conviction for statutory manslaughter if the negligence proximately causes the child's death.
Facts:
- Walter Williams was the stepfather and Bernice Williams was the mother of a 17-month-old child, William Joseph Tabafunda.
- Around September 1, 1968, the child became ill, exhibiting symptoms including fussiness, inability to keep food down, and a swollen cheek.
- The child's cheek eventually turned a bluish color, and the swelling persisted.
- The Williamses believed the child had a toothache and provided him with aspirin, but they did not seek professional medical attention.
- They refrained from contacting a doctor due to their fear that the Welfare Department would take the child away from them.
- The child's condition was caused by an abscessed tooth that led to a gangrenous infection of his mouth and cheek, malnutrition, and ultimately fatal pneumonia.
- The child died on September 12, 1968.
- Walter Williams had previously sought and obtained medical care for the same child for a different issue in April 1968.
Procedural Posture:
- Walter and Bernice Williams were charged with manslaughter by information in a Washington state trial court.
- Following a bench trial, the court entered findings of fact and conclusions of law.
- The trial court found both defendants guilty of manslaughter and imposed sentences.
- The Williamses, as appellants, appealed the judgment and sentence to the Court of Appeals of Washington, the intermediate appellate court.
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Issue:
Does the failure of a parent or guardian to provide necessary medical care for a dependent child constitute statutory manslaughter if that failure is based on simple or ordinary negligence and proximately causes the child's death?
Opinions:
Majority - Horowitz, C.J.
Yes, the failure of a parent or guardian to provide necessary medical care for a dependent child constitutes statutory manslaughter if that failure amounts to simple or ordinary negligence and proximately causes the child's death. The court reasoned that parents have a natural, common law duty to provide medical care for their children, which exists independently of any statute. Under Washington's manslaughter statutes, a conviction can be based on ordinary negligence, which is the failure to exercise the 'ordinary caution' that a person of reasonable prudence would use under similar circumstances. The defendants' subjective ignorance and fear of losing their child were not legally recognizable excuses. The objective evidence of the child's worsening symptoms, including a swollen and discolored cheek, was sufficient to put a reasonably prudent person on notice of the need for medical attention in time to save the child's life.
Analysis:
This case is significant for establishing that simple or ordinary negligence, rather than a higher standard like gross negligence or willfulness, is sufficient for a manslaughter conviction when a parent's failure to provide medical care results in a child's death. It solidifies the application of an objective 'reasonably prudent person' standard to evaluate the parent's conduct, rendering their subjective beliefs or ignorance legally irrelevant if their actions fall below this standard. This holding clarifies that the duty of care is a fundamental common law principle applicable to anyone assuming a parental role and lowers the threshold for criminal liability in child neglect cases resulting in death.
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