Thursday, November 21, 2013

State v. Williams case brief

State v. Williams case brief summary
484 P.2d 1167 (1971)

Defendants appealed from a Superior Court for King County (Washington) judgment convicting them of statutory manslaughter after the court found that they were negligent in failing to support their minor child with necessary medical attention.

The trial court convicted defendants of manslaughter after finding that they were negligent by failing to provide their minor child with reasonably necessary medical attention even though defendants were ignorant as to the seriousness of the child's illness.

  • The appellate court affirmed defendants' convictions, holding that defendants were properly convicted of manslaughter even absent a finding that their misconduct was willful because defendants breached the statutory duty set forth in Wash. Rev. Code § 26.20.030 without lawful excuse or justification. 
  • The court held that, applying the standard of ordinary caution, defendants were put on sufficient notice of their child's illness to have required them to obtain medical care for the child, that their failure to do so was ordinary or simple negligence, and that such negligence was sufficient to support their manslaughter convictions.

The appellate court affirmed defendants' manslaughter convictions and held that defendants were put on sufficient notice of their minor child's illness and accordingly their failure to seek medical attention for their child was simple or ordinary negligence and such negligence was enough to sustain defendants' statutory manslaughter convictions.

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