Brothers Grimm: The Willful Child.

I misunderstood this one at first, until my wife pointed me in the right direction.  The Willful Child:

Once upon a time there was a child who was willful and would not do what her mother wished. For this reason, God had no pleasure in her, and let her become ill. No doctor could do her any good, and in a short time the child lay on her deathbed. When she had been lowered into her grave, and the earth was spread over her, all at once her little arm came out again and reached upward. And when they had pushed it back in the ground and spread fresh earth over it, it was all to no purpose, for the arm always came out again. Then the mother herself was obliged to go to the grave and strike the arm with a rod. When she had done that, the arm was drawn in, and at last the child had rest beneath the ground.