prohibited by statute and to provide adequate standards for adjudication.’ Syllabus Point 1, State v. Flinn, 158 W.Va. 111, 208 S.E.2d 538 (1974).” Syllabus Point 1, State v. Bull, 204 W.Va. 255, 512 S.E.2d 177 (1998). Because the statutory reference to “child” in W.Va. Code § 61-8D-4a does not include any mention of an “unborn child” or a “fetus,” Ms. Louk could not reasonably have known she could be prosecuted for child neglect based on her prenatal conduct. See Georgia v. Luster, 204 Ga.App. 156, 419 S.E.2d 32, 34 (1992) (pregnant woman could not have known use of illegal drugs that affected the fetus could subject her to criminal prosecution). The conduct prohibited by W.Va. Code § 61-8D-4a is neglect resulting in the death of a child. 75 Cal.App.3d 214, 141 Cal.Rptr. 912 (1977) (<HOLDING>). In conformance with the overwhelming majority
holding a mother may not be held criminally liable under a reckless endangerment statute for the effect that prenatal ingestion of a controlled substance may have on her child pre or postbirth holding that mother may not be prosecuted criminally for child endangerment for prenatal substance abuse holding a mother not criminally liable for child endangerment for ingesting heroin while pregnant holding that mother could not be prosecuted under child abuse statute for prenatal use of heroin holding a mother was not criminally liable for knowingly causing injury to a child under circumstances likely to produce death or serious physical injury after the mothers prebirth ingestion of heroin caused her child to suffer heroin withdrawal symptoms postpartum