## Facts

- Jeffrey and Marci Beagley’s 16-year-old son, Neil, had a rare congenital condition causing progressive kidney failure.
- By at least March 2008, Neil’s condition worsened; he became increasingly weak, could not keep food down, and had difficulty breathing.
- The family, based on religious beliefs shared by Neil, relied on faith healing (prayer, laying on of hands, anointing with oil) rather than conventional medical treatment.
- Neil temporarily improved at least once, but his condition progressed and he died on June 17, 2008 from complications of kidney failure.
- Evidence indicated that medical intervention during the week before Neil’s death would have saved his life.
- The state charged each parent with criminally negligent homicide, alleging they caused Neil’s death by failing to provide adequate medical care in violation of a parent’s duty.
- At trial, the court admitted evidence concerning the prior death of the defendants’ granddaughter following a failure to obtain conventional medical treatment.
- A jury convicted both defendants, and they appealed.

## Issues

1. Whether the indictments sufficiently alleged criminally negligent homicide by omission, including adequate notice of the parental duty and the alleged failure to provide medical care.
2. Whether the jury should have been instructed that a parent’s duty to obtain lifesaving medical care arises only when the risk of death is “imminent.”
3. Whether admitting evidence of the granddaughter’s prior death was improper propensity evidence or unfairly prejudicial.
4. Whether applying generally applicable criminal-negligence laws to parents who relied on faith healing violated constitutional religious-freedom protections.

## Decision

- The Oregon Court of Appeals affirmed both convictions for criminally negligent homicide.
- The indictments adequately stated a crime and provided sufficient notice by alleging death caused by failure to provide adequate medical care in violation of a parental duty.
- The trial court did not err by declining to impose an “imminent danger” threshold in jury instructions; criminal negligence turns on a substantial and unjustifiable risk, not imminence.
- Evidence about the granddaughter’s death was admissible for non-propensity purposes (including knowledge of risk and foreseeability) and was not reversible error under the prejudice/probative-value balance.
- The statute was applied as a neutral law of general applicability regulating conduct, not religious belief, and its application did not violate constitutional protections.

## Legal Principles

- Criminally negligent homicide occurs when, with criminal negligence, a person causes the death of another.
- Criminal negligence is a failure to be aware of a substantial and unjustifiable risk, where that failure is a gross deviation from reasonable care in the circumstances.
- Parents have a legal duty to provide necessary medical care to minor children; breach of that duty can supply the omission underlying homicide liability when statutory causation and criminal negligence are proved.
- Criminal negligence does not require that the risk of death be “imminent”; a substantial and unjustifiable risk may develop over time in the face of serious, progressive illness.
- Evidence of prior events may be admitted to prove knowledge, foreseeability, or absence of mistake, and is not barred solely because it may also suggest character, so long as it is used for a legitimate purpose and not unfairly prejudicial.
- Religious motivation does not exempt parents from generally applicable criminal laws requiring reasonable care for a child’s health and safety.

## Conclusion

The court upheld the parents’ criminally negligent homicide convictions, concluding that Oregon law permits liability where parents, despite religiously motivated reliance on faith healing, fail to obtain medical care for a seriously ill child in the face of a substantial and unjustifiable risk of death, and that the indictment, jury instructions, and key evidentiary rulings were legally sufficient.


State v. Beagley, 257 Or. App. 220, 305 P.3d 147 (Or. Ct. App. 2013)