The Oregon Court of Appeals denied an appeal Wednesday from an Oregon City couple who claimed the judge who handled their case improperly allowed jurors to hear prejudicial testimony and that they had no legal duty to provide medical care for their child.
Jeffrey and Marci Beagley were convicted of criminally negligent homicide in 2010 for the death of their 16-year-old son, Neil. They each served a 16-month prison sentence.
The Beagleys and their extended family are members of the Followers of Christ, Oregon City faith-healing church. They did not use doctors for medical care, believing it shows a lack of faith in God. Instead they rely on spiritual treatment: prayer, fasting, anointing with oil and the laying on of hands.
The Beagleys testified that they knew Neil was ill two weeks before he died in June 2008 from complications of a urinary tract blockage. Despite the boy's failing health, the Beagleys didn't take Neil to a doctor. Instead, they decided to honor the boy's wish to put his fate in God's hands.
Doctors testified the boy would have lived had he been treated in his last days.
The Beagleys also were present when their 15-month-old granddaughter, Ava Worthington, died of complications from pneumonia and a blood infection, both treatable conditions in March 2008.
The couple argued that the trial court judge erroneously denied their motion to exclude evidence.
The appeals court found otherwise.
"The fact that defendants had witnessed the death of another child due a to lack of medical care makes it more probable, not only that they did know that Neil was at risk, but that they should have known that Neil was at risk," the court said. "It was directly relevant to the charge of negligence."
Likewise, the court said, the jury instructions were appropriate.
The Beagleys also challenged their criminal indictments, arguing that they were improperly charged.
At the time of Neil's death Oregon law provided limited protection for faith-healing practitioners. The Beagleys said the duty to provide necessary medical care to a child is required by law and even if they did, the law violated the constitutional guarantee of religious freedom.
Lead prosecutor, Greg Horner, successfully argued that those protections, which since have been eliminated by the Legislature, did not extend to parents who fail to provide adequate medical care for their children.
Horner declined comment on Wednesday's decision. Wayne Mackeson, a defense attorney who argued the Beagleys' appeal, did not return calls to his office.
The appeals court said Oregon's criminal negligence statutes were correctly applied in the Beagley case.
State and federal courts have consistently ruled that parents have a legal responsibility .
The Oregon Appeals Court ruled in 1998 that a parent has an absolute duty to provide needed medical care to a child.
The earlier case involved a child who died after his parents withheld medical care and relied solely on faith healing.
"The statutes permit a parent to treat a child by prayer or other spiritual means so long as the illness is not life threatening," the appeals court said. "However, once a reasonable person should know that there is a substantial risk that the child will die without medical care, the parent must provide that care, or allow it to be provided, at the risk of criminal sanctions if the child does die."
The Beagley appeal offered "no compelling reason now to conclude that parents do not have a legal obligation to provide needed life-sustaining medical care for their children, nor that parents' constitutional right freely to exercise their religion encompasses a right unreasonably to fail to meet that obligation," the appeals court said.
