## Facts

- An 11-year-old child developed severe symptoms later determined to be juvenile-onset diabetes and progressively worsened over several days.
- The child’s mother and stepfather practiced Christian Science and chose prayer and spiritual treatment instead of obtaining medical care.
- The parents involved Christian Science caregivers and sought guidance from religious sources, but no physician was consulted and no conventional medical treatment was provided.
- The child died at home in May 1989 from ketoacidosis due to untreated juvenile-onset diabetes.
- A grand jury indicted both parents for second-degree manslaughter based on culpable negligence causing death by failing to obtain necessary medical care.
- The defense moved to dismiss, arguing that a child-neglect statute’s “spiritual means or prayer” exemption authorized their conduct and that applying manslaughter in this setting violated due process fair-notice requirements.
- The trial court dismissed the indictments; the Minnesota Court of Appeals affirmed on due process grounds; the Minnesota Supreme Court granted review.

## Issues

1. Whether a child-neglect statute’s “spiritual means or prayer” exemption limits or precludes prosecution for second-degree manslaughter when parents rely on spiritual treatment and a child dies.
2. Whether applying the second-degree manslaughter statute in these circumstances violates due process fair-notice requirements.
3. Whether reading the neglect exemption together with the manslaughter statute (in pari materia) is required to avoid unconstitutional ambiguity.

## Decision

- The Minnesota Supreme Court reversed the court of appeals and the trial court and reinstated the second-degree manslaughter indictments.
- The court held the spiritual-treatment exemption in the child-neglect statute did not apply to, and did not restrict, the manslaughter statute.
- The court rejected the claim that prosecuting under the manslaughter statute deprived the defendants of fair notice.

## Legal Principles

- A statutory exemption addressing child neglect does not automatically create immunity from homicide liability arising from a child’s death.
- Statutes are read in pari materia only when they address the same subject in a way that warrants harmonized construction; a neglect provision and a manslaughter provision with distinct purposes and elements need not be combined.
- Due process fair-notice requirements are satisfied when the charged criminal statute clearly describes prohibited conduct; the existence of a separate statutory exemption does not negate notice where the statutes do not conflict on the offense’s elements.
- Neutral, generally applicable criminal laws may be enforced even when the charged conduct is religiously motivated, absent targeting of religion.

## Conclusion

The Minnesota Supreme Court held that Minnesota’s prayer-based exemption within its child-neglect law did not shield parents from second-degree manslaughter prosecution when their failure to obtain medical care allegedly caused their child’s death, and it reinstated the indictments after rejecting a due process fair-notice challenge.


State v. McKown, 475 N.W.2d 63 (Minn. 1991)