State v. Williams

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Facts: The D's were the mother and step-father of the victim. The 17-month baby developed an abscessed tooth, which became infected, then gangrenous, which led to pneumonia, which led to the baby's death.

Procedural History: D's were charged with and found guilty for manslaughter, for negligently failing to supply their baby with medical care.

Issue: Where the parents guilty of simple or ordinary negligence? In other words, did the parent's duty to furnish medical care to their child activate before it would have been too late to save the baby's life?

Arguments: The parents loved their child and made an honest mistake in not taking their baby to the doctor. They thought he wasn't sick enough to warrant it. They also thought that the baby would be taken away from them because they weren't taking care of him like they should.

Holding: The D's were found to be negligent.

Reasons: A reasonable person would have realized the need to give the baby medical attention in time to save him.

Judgment: Affirmed

Comments: The state of Washington only required that simple or ordinary negligence be found to uphold a conviction of manslaughter; gross negligence was not required.