She died in early 1977 after medical neglect while still in prison.
"The allegations against the parent were medical neglect," he said.
"There must be an understanding that a parent who would commit educational and medical neglect is at risk to physically abuse children as well."
A common outcome of medical neglect is failure to thrive in infants and children.
These include cases of medical neglect and forced sterilization.
The juvenile court found the parents guilty of medical neglect and ordered Cherrix back into conventional treatment.
His parents were charged with medical neglect as a result of this decision.
But if that case was an extreme example of medical neglect, there have been a regular string of problems at prisons large and small.
Thousands of Chinese children die in orphanages every year from deliberate medical neglect and starvation.
A court can take away parents' decision making authority if they demonstrate medical neglect or abuse.