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State v. Williams
Washington Court of Appeals
484 P.2d 1167 (1971)
Native Americans Walter and Bernice Williams (defendants) were married. Walter was 24 years old, and Bernice was 20 years old. Before they were married, Bernice had two children. The younger child, William, became sick when he was about 17 months old. William had an abscessed tooth that developed into an infection of the mouth and cheeks. Walter and Bernice attempted to treat the problem using aspirin. William’s cheek started swelling up, and he was not able to keep his food down. William’s cheek also started turning a bluish color. William’s tooth then became gangrenous, and his resistance was reduced due to malnutrition. After this, William suffered from pneumonia and died. Walter and Bernice did not take William to the doctor because they did not realize how sick he was. Walter did not believe that a doctor or dentist would pull the tooth when the cheek was swollen. Walter and Bernice were also afraid that if they went to the doctor, they would be reported to the welfare department, and William would be taken away from them. If William had received medical treatment soon after developing gangrene, which has a particular odor, then the doctors could have treated his abscessed tooth and saved his life. The State of Washington (plaintiff) charged Walter and Bernice with manslaughter for negligently failing to provide medical care to William. The trial court found Walter and Bernice guilty, and they appealed.
Rule of Law
Holding and Reasoning (Horowitz, C.J.)
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