State v. Williams
Court of Appeals of Washington
4 Wash. App. 908, 484 P.2d 1167 (1971)
Walter and Bernice Williams (defendants), a young couple with limited education, cared for Bernice's 17-month-old son, who developed an untreated infected tooth over about two weeks that spread and became gangrenous, eventually causing malnutrition and death from pneumonia; the couple treated the child only with aspirin, out of fear that seeking medical help would cause the state to take the child away, and testified they did not realize how serious his condition was. Convicted of manslaughter after a bench trial, the Williamses appealed, arguing the state failed to prove their negligence caused the child's death.
Whether a person is guilty of involuntary manslaughter if he commits ordinary negligence — failing to exercise the caution a reasonable person would exercise under the same circumstances — that proximately causes another's death.