## Facts

- Laurie Grouard Walker, a Christian Scientist, was the mother of a four-year-old child, Shauntay.
- Shauntay became ill with flu-like symptoms and later developed a stiff neck; Walker chose prayer treatment instead of medical care.
- Walker contacted a Christian Science prayer practitioner and a Christian Science nurse, who provided prayer and nursing care on several occasions.
- Over approximately 17 days, Shauntay lost weight, became disoriented and irritable, and died from acute purulent meningitis without receiving medical treatment.
- The prosecution charged Walker with involuntary manslaughter (criminal negligence causing death) and felony child endangerment.

## Issues

1. Whether statutory provisions permitting spiritual treatment by prayer in certain contexts immunize a parent from prosecution for involuntary manslaughter and felony child endangerment when a child dies after no medical care is provided.
2. Whether the manslaughter and felony child-endangerment statutes, considered alongside statutory prayer-treatment language, failed to provide fair notice that Walker’s conduct could be criminal, violating due process.
3. Whether prosecuting a parent for withholding medical care based on sincere religious beliefs violates federal or state constitutional protections for free exercise of religion.

## Decision

- The court denied pretrial writ relief and allowed the prosecution to proceed.
- Statutory prayer-treatment language in a misdemeanor failure-to-support statute did not bar prosecution for involuntary manslaughter or felony child endangerment.
- The statutes provided constitutionally adequate notice and were not unconstitutionally vague as applied.
- Applying neutral criminal laws protecting children from serious harm or death did not violate free-exercise protections.

## Legal Principles

- A statutory exception or proviso is ordinarily limited to the offense defined by that statute and does not implicitly redefine or negate elements of separate crimes.
- Absent an express legislative grant, courts will not infer immunity from homicide or felony child-endangerment liability based on narrow spiritual-treatment clauses in other statutes.
- Due process is satisfied when criminal negligence standards give reasonable notice that omissions creating a substantial risk of death or serious bodily injury—such as failing to obtain medical care for a gravely ill child—may be prosecuted.
- The state’s interest in protecting children’s life and bodily integrity justifies applying neutral, generally applicable criminal laws even when compliance conflicts with parental religious practice.

## Conclusion

The court held that California law did not exempt prayer-only parental treatment from criminal liability for a child’s death and that due process and free-exercise protections did not require dismissal, permitting prosecution for involuntary manslaughter and felony child endangerment to go forward.


Walker v. Superior Court, 47 Cal. 3d 112 (Cal. 1988)