State v. Williams 4 Wash.App. 908, 484 P.2d 1167 (1971) Mr. and Mrs. Williams' baby wasn't feeling well. They figured it was just a toothache so they gave it an aspirin. Turns out it was a serious problem and the baby died. The couple was not very well educated, but seemed to care about their child. Mr. and Mrs. Williams were arrested and charged with involuntary manslaughter. The Trial Court convicted them of (statutory manslaughter) involuntary manslaughter. They appealed. The Trial Court found that the couple negligently caused the death of their child by not seeking medical attention. The couple argued that they figured they infection would go away by itself, and were worried that if they took a sick baby to the hospital, the welfare department would accuse them of neglect. The Appellate Court upheld the conviction. The Appellate Court noted that under the common-law, in order to amount to involuntary manslaughter, a person's conduct had to amount to "more than mere ordinary or simple negligence, gross negligence was essential." Aka recklessness. However, under Washington State law, ordinary negligence is enough to make one criminal culpable for manslaughter. Under Washington State law, if a person has a duty to care, and doesn't use the caution that an ordinary person would (an objective standard), then they are criminally culpable. A few years later, Washington changed their laws. The current Statutes have two degrees of manslaughter; recklessly causing death and causing death by criminal negligence. Washington no longer imposes manslaughter liability in cases involving ordinary negligence.