“Is anyone among you sick? Let them call the elders of the church to pray over them and anoint them with oil in the name of the Lord. And the prayer offered in faith will make the sick person well; the Lord will raise them up. If they have sinned, they will be forgiven. Therefore confess your sins to each other and pray for each other so that you may be healed. The prayer of a righteous person is powerful and effective.” ~~ Jesus Christ (James 5:14-16)
“Congress shall make no law respecting an establishment of religion, or prohibiting the free exercise thereof.” ~~ Constitution of the United States, First Amendment
In a war-ravaged country several thousand miles away, a child has been abducted from his village (along with all other children old enough to walk and talk) and indoctrinated by a militant rebellion. Once suitably trained, he is armed with an automatic rifle, assigned to a battalion consisting of other children roughly his age – 12, maybe 13 years old, including girls – and sent onto a battlefield consisting of villages indistinguishable from his original home. This youth infantry is sent forth on the front lines to massacre the residents with firepower that American children their age know only from video games – a tactic that works for a short while, before the entire platoon of preadolescents is in turn wiped out by the ruling army’s snipers and rocket launchers, as well as strategic placement of landmines throughout the village.
Meanwhile here in the United States, a preverbal toddler writhes in his crib, obviously distressed, his ill condition further evidenced by frequent vomiting and sluggishness. Unable to vocalize his complaints other than through crying incessantly, these manifestations are the only signals to his care providers – his parents – that something is wrong. The parents look down into the crib, noticeably worried about their child’s worsening condition, yet willing to relinquish their nurturing role to another person present in the room, a faith healer from their church. The toddler begins convulsing, which the faith healer praises as proof of the prayers working (in fact, the child’s brain is swelling). When the parents begin to doubt these claims of improvement – doubts further bolstered by the fact that their child refuses to eat and cries incessantly – the faith healer accuses them of having weak faith or “obstructing sins” interfering with the healing. After weeks of progressive deterioration, the parents decide to abandon the faith-healing process and seek expert medical care. Based on the presenting symptoms, the emergency staff immediately suspects meningitis and orders a spinal tap, which confirms their fears. Compounding this bad news is the fact that this is a case of Haemophilus influenzae type B (HiB) meningitis, which unlike viral meningitis requires early identification and quick intervention with intravenous antibiotics in order to reduce mortality. Unfortunately for this child, his parents’ decision to shun medical treatment in favor of intercessory prayer has contributed to his ultimate demise: Unable to be treated effectively, the disease has caused irreversible brain damage, and the child spends his final moments wasting away in a pediatric intensive care unit, eventually succumbing to the disease.
The first instance above is reflective of a real-world scenario – in this case, the atrocities occurring in various regions of East and Central Africa (the example is drawn from a typical story of how the Lord’s Resistance Army – a Christian paramilitary organization – recruits its child soldiers). The subsequent paragraph is an approximate account of what happened to Rita Swan’s toddler son (see Seth Asser and Rita Swan in Pediatrics (1998) and Dr. Stephen Barrett’s “Matthew Swan”). Ms. Swan, once a devout Christian Scientist, had put off medical treatment for her ailing child because of the church’s insistence of the efficacy of prayer. While not much comparison can be made between the above two scenarios, one important facet is shared by these anecdotes, and that is the death of a child (extrapolating from these examples, one can see that deaths of children – plural – is thus implied); furthermore, the deaths in these cases were the direct result of mystical beliefs, and the immensely different worlds in which they take place (Sub-Saharan African/Christian hybrid religions on one hand, and evangelical Christianity popular in middle-class America on the other) demonstrate that the malignant effects of religious belief have no socioeconomic boundaries.
The founding ideals of the Establishment Clause will be revisited and assessed throughout the course of this research paper. Religious freedom is one of the many social and political freedoms afforded to United States citizens, and we have long implicitly defined “citizen” as an adult who is “entitled to the rights and privileges of a freeman,” trusting parents in our society to raise their children with the same respect to individual rights that we afford them as citizens. Thus, any paper on the topic of children of religious parents should give at least a nod to the First Amendment, if not explicitly scrutinizing its meaning(s) and implications in the America of today, where it seems religion is always making headlines and under the perpetually watchful eye of civil rights groups and social organizations.
One inescapable reality of childrearing, either now or at any time in the past, is the fact that kids will get sick and parents will have to decide on an appropriate course of treatment. In modern Western civilizations, the common and accepted practice is to seek the advice of a medical provider such as a doctor or nurse when symptoms warrant or, based on experience and knowledge, choose to monitor the illness and self-treat with traditional methodologies (such as over-the-counter preparations or “watchful waiting”). Not every little cough or elevated temperature is cause for concern, of course, as the human immune system has amazing capabilities for not only warding off infections and fighting disease, but for incredible feats of self-repair even without expert medical involvement. Furthermore, the role of parent carries with it the societal expectation that child abuse and neglect are simply unacceptable and are indeed grounds for various degrees of punishment tailored to the severity of the offense, so if not simply for the sake of being a nurturing parent, one has the added incentive to avoid legal repercussions and societal sanctions.
For a small proportion of religious followers, doctrine trumps everything, including personal well-being or the well-being of one’s children. The material and the earthly (such as drugs) are rejected in certain denominations, and adherents are either admonished against seeking “secular” assistance (like going to the doctor) in lieu of the church’s preferred approach or, in the more extreme sects, are completely barred from addressing health issues via non-faith-based routes at the risk of being ostracized. In this paper, the primary focus will be on two specific Christian denominations that have made headlines frequently over the years because of their stance on faith healing: The Church of Christ, Scientist, and the Followers of Christ, both founded in the late 19th century in the United States. Notably, the Followers of Christ are an offshoot of the Pentecostal branch, which is known for its display of “glossolalia,” or speaking in tongues.
How “free” are practitioners of religious faiths? Does the First Amendment extend protection to someone whose religion mandates human sacrifice? Different kinds of religious rights in the United States have had to be ultimately defined by the Supreme Court. The first case of significance to this research is Reynolds v. United States (1878), in which the Court stated that while it could not legislate against religious belief, it could do so against actions carried out because of a deeply held religious conviction, agreeing with Thomas Jefferson that allowing bigamy (the religious freedom on trial in this particular instance) created a slippery slope, where someone could theoretically profess a belief in human sacrifice and expect the freedom to carry out such a ritual, and allowing such broad and unregulated freedom would undermine the law of the land and give religion more power than the established government (more on the “Moriah problem” later).
Fast forwarding nearly a century, one will encounter the well-known State of Wisconsin v. Yoder (1972), where the Court sided unanimously with the Amish community and stated that Amish children could not be compelled by the government (local, state, or otherwise) to receive public education beyond eighth grade. Of note in the Yoder case is the dissenting opinion of Justice William O. Douglas who, although siding with the Court, had this to say: “I disagree with the Court’s conclusion that the matter is within the dispensation of parents alone. The Court’s analysis assumes that the only interests at stake in the case are those of the Amish parents on the one hand, and those of the State on the other. The difficulty with this approach is that, despite the Court’s claim, the parents are seeking to vindicate not only their own free exercise claims, but also those of their high-school-age children…. On this important and vital matter of education, I think the children should be entitled to be heard.” While this case set precedence for religious freedom, it also severely undermined the rights of children, with the Court asserting that the parents’ First Amendment rights were on trial here, not the children’s, in regards to Justice Douglas’s statement.
Notably, there have been instances where religious organizations have made concessions to secular law (whether obligated to concede by courtroom defeat, or agreeing to conform for the greater good is irrelevant, as the most defiant denominations or individuals will ignore even Supreme Court rulings). In Wisconsin v. Yoder (1972), while we found that the court saw no constitutional reason to force Amish children to receive public education, the Amish have agreed to furnish their horse-drawn carriages with “Slow Moving Vehicle” reflective triangles in exchange for their opportunity to utilize the thoroughfares designed for motor vehicles (of unrelated significance, a sect of Amish have refused to display said triangle and have thus continued to tie up courts in their regions, reflecting the defiant attitude that the most separatist of religions have been observed to display). Another oft-cited case, Prince v. Massachusetts (1944), ruled that parental authority is “not absolute” and that while parents were free to make martyrs of themselves, “The family itself is not beyond regulation in the public interest, as against a claim of religious liberty. And neither the rights of religion nor the rights of parenthood are beyond limitation…The right to practice religion freely does not include the right to expose the community or the child to communicable disease or the latter to ill-health or death…” While this one ruling would seem to provide the government all the constitutional power required to remove children from homes where they are in imminent danger due to neglect, state laws offer varying exemptions and protections regarding child abuse and neglect on religious grounds.
Of all the studies, trials, and research done to test claims of the efficacy of faith healing, prayer, and other religious-based therapies, one particular journal article sticks out (and, in fact, is cited in nearly every future paper covering this topic) – that of Asser and Swan’s “Child Fatalities From Religion-Motivated Medical Neglect,” a paper which analyzed the deaths of 172 children of faith-healing parents and found that “ fatalities were from conditions for which survival rates with medical care would have exceeded 90%. Eighteen more had expected survival rates of >50%. All but 3 of the remainder would likely have had some benefit from clinical help.” The authors conclude that “existing laws may be inadequate to protect children from this form of medical neglect…[as] contacts with public agencies and mandated reporters of suspected child neglect were not unusual among the children.” A 2006 Family Court Review journal article found that since the original 1998 study, Ms. Swan had learned of “more than 100 additional cases,” although conceded that this was not an actual number and that it would be impossible to get precise data (Hirasawa, 2006).
Almost as horrifying as the hard data on these innocent deaths is the anecdotal evidence provided by former practitioners (both that of faith-healing parents like Ms. Swan, as well as the children who suffered under their delusions, sometimes for decades into adulthood) and the eyewitness accounts of well-meaning citizens like teachers and neighbors who wanted or tried to help endangered children, but were powerless in the face of such a powerful abstract entity like that of Religious Freedom. Take, for instance, the introduction of a 2004 research paper by Kenneth S. Hickey and Laurie Lyckholm: “In late Fall of 1992…[Andrew], a twelve-year-old seventh grader…began to experience lethargy, weight loss, and frequent urination. Andrew began to complain to his father and paternal grandmother about his symptoms on or about December 14, 1992. His father, a Christian Scientist, felt his son’s symptoms were transient and made little attempt to address the issue. By December 17, 1992, Andrew was emaciated, vomiting, and eating little. His father contacted a Christian Science practitioner who provided healing prayer without actually coming to see Andrew. By December 20, 1992, Andrew experienced altered mental status and total exhaustion. A Christian Science nurse was called to the family home. Upon her arrival, Andrew was making no eye contact, was unresponsive, and had rapid, deep respirations. At this time, Andrew’s father decided to abandon spiritual healing and called 911. Andrew was transported to the nearest hospital and was pronounced dead. The medical examiner deemed the death to be the result of complications associated with juvenile diabetes.”
What kind of protections do faith-healing parents enjoy? The laws vary from state to state, and Ronald Bullis, in a 1991 paper published in Child Welfare, goes through each state and lists the statutory citations (where applicable) for legal exemptions in cases of medical neglect; at the time of his article (notably two decades ago), he found that “ of the 50 states have statutes that ostensibly exempt from prosecution parents who treat their children’s serious illnesses by spiritual means alone. Although states have imposed limitations upon this exemption, this excuse is still offered as a defense in the death of children” (1991). Thus, one parent who allows his or her child to die of a treatable condition in one particular jurisdiction may receive an exemption, whereas in a different state they may be convicted; however, the number of convictions and severity of convictions, while increasing of late, still pales in comparison to other crimes against children resulting in death, and often the convicted parents appeal or receive reduced sentences because the intent to deliberately cause harm to their children is nearly impossible to establish in a faith defense. Hirasawa (2006) provides updates on some of the exemptions, noting that “life-threatening conditions” in some jurisdictions allows the state to intervene against the parents’ wishes.
A key component in the fight to change existing laws granting seemingly unconditional exemptions to allow children to perish at the hands of the tenets of their parents’ faith is education, namely education on the origins of disease and the varying course that pathologies can take. Ignorance and naiveté in health matters no doubt causes some well-meaning parents to misinterpret what is actually going on in their children. Terence Hines in Pseudoscience and the Paranormal describes known phenomena of disease that can be misleading, notably the notorious “placebo effect” as well as “a nasty little statistical gremlin” known as “regression to the mean,” which basically explains the waxing-and-waning course of many chronic illnesses. While these and other factors can lead to clouded judgment on the part of the observer (parents in this case), Hines takes the stance that faith healers kill people by falsely convincing them of a cure, leading them to believe medical follow-up is unnecessary. While Hines attacks the faith-healing institution as a whole, he does focus on children when discussing the beliefs of the Church of Christ, Scientist (one of several Christian denominations engaging in faith healing): “Parents are forbidden to take their children, no matter how sick, to legitimate physicians, but must let them be treated solely by Christian Science practitioners. As might be expected, this has resulted in the deaths of Christian Scientist children from diseases that could have been treated, and the child’s life saved, had medical attention been provided. The Church…along with many other fundamentalist sects and cults…argues that it is parents’ right to withhold legitimate medical treatment from their children and that they should not be prosecuted…when children die from the lack of such treatment” (Hines, 2003). Not only do faith healers enjoy the various exemptions described by Bullis (1991), but “the Church of Christ, Scientist, lobbies vigorously when attempts are made to eliminate such exemptions” (Hines, 2003).
Is there any foreseeable compromise to this issue? Religious practitioners in the United States will more than likely continue to use the First Amendment to justify their actions (or lack thereof), but how lenient are we as a society willing to be with interpretation of our Bill of Rights? Other amendments have been debated with as much fervor and intensity as the First, and there is always the argument that our founding documents are not open to reinterpretation based on changing norms and mores in society, as well as the argument that we should reinterpret these fundamental papers as often as is necessary. Legal arguments aside, another issue needing to be addressed is the actual efficacy of prayer and faith healing, and the literature on this is rather lacking; indeed, the “top” studies “proving” these methods work proffer no more than anecdotal evidence and subjective accounts of what could best be described as placebo effect. Hines (2003) examines several studies dating back to 1872 regarding allegations of the efficacy of intercessory prayer; empirical data suggests that prayer either has no measurable effect greater than that of control groups, although of significance is that in some studies where groups thought they were being prayed for (that is, they knew prayer was being conducted, whether or not they were actually part of the study group),subjective reports of improvement were deemed supportive of prayer’s effectiveness. In The God Delusion (2006), Richard Dawkins describes the Templeton Foundation-funded study that, as reported in the American Heart Journal of April 2006, showed “no difference between those who were prayed for and those who were not. What a surprise.” Stories of “miraculous” recoveries are abundant, again reflective of the general public’s ignorance of disease processes (as evidenced by cases of spontaneous remission being touted as miracles) and the fact that modern medicine still has a lot of questions to answer. One tactic that probably will not work – and the very idea smacks of an unethical approach – is preemptively removing children of these parents from their homes, although we are left with increasingly fewer options for protecting these children the more willing we are to grant unfettered freedom to religious followers. Dr. Stephen Barrett, founder of the well-known medical fraud watchdog organization “Quackwatch,” also nicely summarizes studies on faith healing (“Some Thoughts About Faith Healing,” 2009), going on to conclude that “laws to protect children from medical neglect in the name of healing should be passed and enforced. In states that allow religious exemptions…these exemptions should be revoked. Maybe the practice of faith healing on minors should be illegal.”
In respecting religious freedom in this country, we have given religious parents free rein to brand their children as belonging to the same religion; in doing so, are we not disrespecting the children’s rights to choose and reject such doctrines as they see fit? Surely some will argue that indoctrinating children is for their own good, for their eternal good, but such assertions fly in the face of reason when children are purposely denied life-saving or even symptom-alleviating treatments, and one has to question the mental stability of a parent who can sit by and do nothing (prayer, in this case, counts as “doing nothing”) while their child cries, asks for help, and begs for the suffering to stop. Dawkins (2006) has lambasted religion in general, but in particular he attacks the assigning of religious identity to children: “[T]he assumption that a six-year-old child can properly be said to have a religion at all…that baptizing an unknowing, uncomprehending child can change him from one religion to another at a stroke seems absurd – but it is surely not more absurd than labelling a tiny child as belonging to any particular religion in the first place.”
Children are dying as a direct result of parental religious convictions, and while progress is being made in the realm of offering legal protections to these innocent victims, it is nearly impossible to overlook the harm that has already been done – a quick perusal of the child fatalities on the website “What’s the Harm?” lists not only the reported cases of child deaths from faith healing, but also from exorcism, neglect due to preference for homeopathic or naturopathic remedies, the anti-vaccination movement, and other controversial faith-based therapies like “reparative therapy” for homosexual children.
So what kind of legal argument could be made to compel these religious parents to seek medical care when their children fall ill? Prince v. Massachusetts (1944) clearly stated that freedom of religious expression “does not include the right to expose the community or the child to communicable disease or the latter to ill-health or death,” and recent convictions – actual prison sentences, not just probation – have given this question new life. Writing the law will presumably be a tricky and lengthy endeavor, since a law targeting a specific religion or denomination would be discriminatory on the court’s part (see the Supreme Court-overturned municipal law outlawing animal sacrifice in Church of the Lukumi Babalu Aye v. City of Hialeah (1993), where the law was deemed to not cover all instances of animal cruelty, religious or not, which was its stated purpose). States that have struck down previously existing religious exemptions for child abuse/neglect have tried different methods to protect children. In a 1998 Time article by David Van Biema, he describes a type of passive monitoring of faith-healing religions (“requiring parents to alert authorities if their medical boycott endangered their children”) implemented by Minnesota in 1994: “A check on the state’s biggest county shows that no one has self-reported.” So even in states where laws have become stricter, most extremist sects are unlikely to comply with secular law when it interferes with their beliefs, thus making such measures futile.
Active monitoring of religious denominations known to engage in or encourage faith healing seems the most logical approach to preventing further child deaths from preventable diseases (recall the 172 deaths studied by Asser and Swan, of which 169 would have most likely have lived with proper medical intervention), as well as preemptively addressing the deliberate avoidance of child-health mandates. Most health insurance companies will (in the very, very fine print in your benefits plan) have a list of excluded conditions – diseases that are covered under no circumstances, no matter how much you have paid in premiums over the years. I would suggest similar terminology in writing our laws, but reversed – instead of excluded conditions, all citizens (to avoid the law being overturned as discriminatory against a particular sect) would need to be aware of “inclusive symptoms and conditions” that would require analysis and interpretation by a legitimate healthcare provider (a list that would obviously require perpetual amending, a daunting proposition in itself). Since some of the perpetrating religions will go to great lengths to even avoid diagnosis (“diagnosis” being dependent on the analysis of a medical doctor), the law would need to cover telltale signs and symptoms that would need to be assessed if they persist for a certain time – thus, a public school student with persistent lethargy and an acetone or fruity odor about himself, and whose parents are Christian Scientists, would be legally required to seek medical care (the aforementioned symptoms are indicative of diabetic ketoacidosis, a very serious complication of untreated diabetes), and could be reported by any school official without fear of repercussions. Anti-faith-healing legislation would also presumably need to include language to cover folk remedies such as complementary and alternative medicine (CAM), traditional Chinese medicine (TCM), exorcism, certain religious diets, and other prayer-centric faiths outside of Christianity.
Socially, great strides need to be made. Our liberal culture has been willing to offer huge freedoms to a vast array of religions (even including animal sacrifice in Florida as noted in Lukumu Babalu Aye v. Hialeah), but at what cost? To use an extreme hypothetical (at least, hypothetical to my knowledge): What if a religion came forward called “Moriahinism,” after the Moriah mountains where Abraham was ordered to sacrifice his only son to God; what if the founding doctrine of this religion was that all adherents were to take their firstborn to the highest point within reach (understanding that not all followers will have access to the mountain of lore), bind them to an altar, and slaughter them with a sacrificial knife – unless, of course, an angel intervened at a crucial faith-defining moment? This sounds like a ridiculous religion, but based on the inconsistency of American laws covering faith and the fact that the highest court in the land has ruled both in favor of and against religious expression, is it that inconceivable that someone could come forward tomorrow – with documentation that their religion has existed for at least a few generations and is thus “legitimate” – and demand the right to carry their children to a mountain for sacrifice? Most of us would be appalled at the idea of permitting such a thing in our society, but “religious freedom” has become such an abstract concept that proponents tend to lump belief and expression into the same “right.”
My proposition is not to outlaw these extremist faiths, no matter how ideal that situation would be. However, from a constitutional and human rights perspective, I feel that these children are entitled to the same rights as voting-age citizens, and as such should be permitted (even encouraged, but let’s start small!) to break free from the shackles of their parents’ faith in order to continue their earthly existence, no matter how trivial or insignificant said existence is deemed to be in the tenets of the family beliefs. Furthermore, I fear that a society-wide branding of these faiths as “cults” could potentially lead to a congregation secluding itself indefinitely or worse, leading to either a domestic situation like the Branch Davidians in Waco, Texas, in 1993, or a church-wide exodus such as the Jonestown incident (while both of those examples are extreme, they highlight the degree to which a cult will go when completely ostracized by society).
After leaving Christian Science, Rita Swan went on to form Children’s Healthcare Is a Legal Duty (CHILD), an educational charity “founded in 1983 to protect children from harmful religious and cultural practices, especially religion-based medical neglect. CHILD believes laws should protect all children equally and opposes religious exemptions from child health and safety laws.” On the CHILD website, various databases catalogue the deaths of children due to religious beliefs and other “folk remedies,” and a quick perusal of the list under “religion-based medical neglect” shows a pattern – not only the usual suspects of Christian Science and Followers of Christ (as well as others like Jehovah’s Witnesses and the Amish), but a large proportion of the links to various trials and news reports indicate that religious exemptions permit these preventable deaths to occur (“Iowa religious exemption to lead screening,” “Foster child deprived of vaccines on religious grounds,” “Witness child allowed to die without transfusion”). Since the time that Bullis (who, it should be noted, is a PhD legal scholar and a clergyman) published his paper in Child Welfare showing state-by-state religious exemptions, some states have changed the laws on their books, but advocates for stricter laws protecting children are still dissatisfied. Thus, non-religious neglect is eagerly prosecuted (and rightfully so), but once religion enters the equation the courts are more prone to allow some measure of child suffering because of some fanciful, unverifiable thoughts floating around in the parents’ heads.
In cases of “religion-motivated medical neglect,” it is often difficult to show intent to cause harm to the child, as is often easily proven in cases of blatant child abuse; that is, a child who suffers from a treatable illness that is only treated with prayer will probably not display overt signs of trauma like belt buckle-shaped bruises or cigarette burns (to use oft-cited signs of some of the worst abuse), but despite the difference in intent, instances of faith healing and intentional assault share a glaring similarity – children suffer and occasionally die.
Perhaps the courts are not the solution. Perhaps, as Daniel Dennett points out in Breaking the Spell: Religion as a Natural Phenomenon, the solution lies in society’s attitude:
How can we hope to compete with the promise of salvation and the glories of martyrdom? We could lie, and make promises of our own that could never be fulfilled in this life or anywhere else, or we could try something more honest: we could suggest to them that the claims of any religion should, of course, be taken with a grain of salt. We could start to change the climate of opinion that holds religion to be above discussion, above criticism, above challenge…if we start holding religious organizations accountable for their claims – not by taking them to court but just by pointing out, often and in a matter-of-fact tone of voice, that of course these claims are ludicrous – perhaps we can slowly get the culture of credulity to evaporate.
Or we can continue to stand by and allow religion to abduct children from the “village” of society, indoctrinate them, and send them to certain death…landmines or diabetes, what’s the difference?
Asser, S.M., and Swan, R. (1998). Child fatalities from religion-motivated medical neglect. Pediatrics, 4(101), 625-29.
Barrett, S. (2009). Matthew Swan. Retrieved from http://www.quackwatch.com/01QuackeryRelatedTopics/Victims/matthew.html
Barrett, S. (2009). Some thoughts about faith healing. Retrieved from http://www.quackwatch.com/01QuackeryRelatedTopics/faith.html
Bullis, R. K. (1991). The spiritual healing “defense” in criminal prosecutions for crimes against children. Child Welfare, 70(5), 541-55.
Church of the Lukumi Babalu Aye v. City of Hialeah, 508 U.S. 520 (1993).
Constitution of the United States, First Amendment.
Dawkins, R. (2006). The god delusion. New York, NY: Houghton Mifflin Company.
Dennett, D. C. (2007). Breaking the spell: Religion as a natural phenomenon. (p. 335). New York, NY: Penguin Group USA.
Hickey, K.S., and Lyckholm, L. (2004). Child welfare versus parental autonomy: Medical ethics, the law, and faith-based healing. Theoretical Medicine and Bioethics, 25(4), 265-76.
Hines, T. (2003). Pseudoscience and the paranormal. (2nd ed.). Amherst, NY: Prometheus Books.
Hirasawa, K. R. (2006). Are parents acting in the best interests of their children when they make medical decisions based on their religious beliefs?. Family Court Review, 44(2), 316-29.
Prince v. Commonwealth of Massachusetts, 321 U.S. 158 (1944).
Reynolds v. United States, 98 U.S. 145 (1878).
State of Wisconsin v. Jonas Yoder, Wallace Miller, and Adin Yutzy, 406 U.S. 205 (1972).
Swan, R. (n.d.). Children’s healthcare is a legal duty. Retrieved from http://www.childrenshealthcare.org/
Van Biema, D. (1998, August 31). Faith or healing?. Time, 152(9), 68.
What’s the harm in being a child?. (2009). Retrieved from http://whatstheharm.net/children.html