State v. Williams

484 P.2d 1167 (1971)

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State v. Williams

Washington Court of Appeals
484 P.2d 1167 (1971)

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Facts

Native Americans Walter and Bernice Williams (defendants) were married. Both were in their early twenties and had little formal education. Bernice had two children before the couple got married. When the younger child, William, was about 17 months old, he got a toothache. The toothache escalated into an abscessed tooth, then a serious infection of the mouth and cheeks, then gangrene, and ultimately pneumonia. Walter and Bernice attempted to treat the problem using aspirin. Because William could not keep food down as a result of his condition, he became malnourished and unable to fight his worsening infection. William died of pneumonia two weeks after his initial toothache. Walter and Bernice did not take William to the doctor because they feared that the state would take him away. At the time, racial stereotypes had contributed to the breakup of many Native American families in Washington, and the couple knew another family that had lost custody of its sick child. In addition, both Bernice and Walter were unaware of the seriousness of William’s worsening condition until he died. William’s gangrene, which has a particular odor, was likely present about 10 days before his death. If William had received medical treatment in the week before his death, doctors could have saved his life. Bernice and Walter were both charged with involuntary manslaughter. The trial court found that both Bernice and Walter were negligent in failing to get William proper medical care and that their negligence proximately caused his death. Bernice and Walter were convicted of involuntary manslaughter, and they appealed.

Rule of Law

Issue

Holding and Reasoning (Horowitz, C.J.)

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