Oregon v. Hickman
Annotate this CaseDefendants Dale and Shannon Hickman were convicted of second-degree manslaughter after they declined to seek medical treatment for their son David, who died about nine hours after he was born prematurely. Defendants are members of the Followers of Christ Church, which encourages its members to rely on God to heal sickness and injury, and considers resorting to conventional medicine as a failure in faith. At trial, defendants argued that, because they withheld medical treatment from David based on their religious beliefs, the Oregon Constitution required the state to prove that they "knew" David would die if they relied on prayer alone and, despite that knowledge, failed to seek medical treatment for him. The trial court disagreed and allowed the state to proceed on a theory of "criminal negligence," consistently with the statute defining second-degree manslaughter by neglect or maltreatment. The Court of Appeals summarily affirmed. The Supreme Court granted review to consider whether the state must prove that a criminal defendant acted with "knowledge" that an unlawful result would follow when that defendant's conduct was motivated by a sincerely held religious belief. The Court concluded that it does not.
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