Near v. Minnesota Precedents:

1. Regina v. Wagstaff (10 Cox Crim. Cases, 531): "The parents of a sick child, who omitted to call in medical attendance because of their religious belief that what they did for its cure would be effective, were held not to be guilty of manslaughter." because they took a negative and not a positive action towards their child.
2. Article IV Section 3 of the U.S. Constitution gave Congress the authority to enact laws in the territories of the United States.