Case BriefCrim law, Homicide, Involuntary ManslaughterHughes, 2/21/15Identity of CaseState v. Williams, 484 P.2d 1167 (Wash. Ct. App. 1971)Page 390 of the casebookSummary of Facts/Procedural HistoryWilliams are native americans with a less than high school education. Their baby developed a toothache,which they did not seek treatment for because they believed the gov’t would take away their baby if they took it to the hospital (probably true). Toothache grew worse until it died. Convicted of involuntary manslaughter via negligence. Appealed based on (1) existence of duty to furnish medical care and (2) proximate cause, i.e. whether defendants were put on notice in time to save the baby’s life. Statement of the Issuesee above. HoldingYes there is a duty to provide medical care to your children. Proximate cause: if defendants were put on notice in time to save their baby, as the court finds they were, there is proximate cause. ReasoningThis is a timing issue. If a reasonable person would’ve realized it was more than a toothache in time to save the baby, then failure to provide care is the proximate result. If they provided care but it was too late, or were reasonably put on notice too late, no proximate cause. The court thinks they were put on notice early enough to save the baby, so there is proximate cause. Negligence as involuntary manslaughter: failing to perform a duty which a reasonable person would do.
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