Case brief summary
Parents must get medical care for their children. Under manslaughter law, ordinary carelessness, not using the caution a reasonable person would use, can be enough for a conviction.
Facts
Walter and Bernice Williams cared for Bernice's toddler, who had an infected tooth that led to gangrene and fatal pneumonia. They noticed he was sick for two weeks but didn't take him to a doctor.
Procedural history
Parents were charged with manslaughter for not getting medical care for their child, who died. A judge convicted them after a trial without a jury, and they appealed.
Issue
Did the parents' failure to seek medical care, done without realizing how serious the child's condition was, still count as a legal violation serious enough to support a manslaughter conviction, and did that failure actually cause the child's death?
Holding
The court upheld the convictions, ruling that parents have a duty to get medical care for their children, and ordinary carelessness in failing to do so can count as manslaughter.
Reasoning
The law says a killing is only excusable if the person used the caution a reasonably careful person would use. Falling short of that, even without intending harm, is enough for manslaughter.
Opinions
Majority (Horowitz, C.J.): Parents and caretakers have a duty to provide medical care, and ordinary carelessness in breaching that duty can support a manslaughter conviction.
Concurrences (Utter and Williams, JJ.): Both judges agreed with the majority's decision without writing a separate explanation.