Florida appeals court reverses both convictions in hot-car baby death

Prosecutors rarely bring felony murder charges in accidental child deaths

A Florida appeals court on Wednesday overturned both of Rhonda Jewell’s convictions tied to the 2023 hot-car death of 10-month-old Ariya Paige — a third-degree felony murder conviction and a separate leaving-a-child-unattended conviction — ruling that both charges required proof Jewell knowingly left the baby in the vehicle. The First District Court of Appeal ordered the case remanded to the trial court for a new proceeding.

Jewell, 46, was babysitting four children from two families in July 2023 when she forgot Ariya was strapped into a rear-facing car seat in the back of her car and went inside to care for the other children. Ariya died of hyperthermia before Jewell realized her mistake, according to court records and the appellate opinion.

The following year, Jewell was convicted of third-degree felony murder, predicated on the underlying felony of leaving a child unattended in a vehicle, and sentenced to 17 years in prison. But the same jury that convicted her acquitted her of aggravated manslaughter — the only charge that required jurors to find Jewell had acted with reckless disregard for the baby’s life.

In its opinion Wednesday, the appellate court focused on the legal structure of the conviction. “Third-degree felony murder cannot be based on an unenumerated predicate felony that does not require any proof of intent,” the court wrote. The panel added: “This case highlights how imperfect our criminal justice system is to adjudicate an accidental death. There are no winners here; moral outrage is not assuaged. And beneath the tragedy, the issues are legally important.”

The charges against Jewell represented an attempt to dramatically expand the felony murder doctrine — a sweeping legal theory in which any individual involved in a felony that leads to a death can be held criminally responsible for that death. Nearly every state, as well as the federal government, has some form of a felony murder rule. These statutes have produced stark outcomes: women being convicted of murders committed by their abusers, friends of a 19-year-old who was killed by law enforcement being charged with his death, and a man being held responsible for a fatal accident that occurred while he was handcuffed in the back of a police car miles away.

Defenders of the doctrine argue that even if an individual did not intend to kill anyone, the choice to commit a felony that resulted in death should carry responsibility for the harm. But Jewell’s case represented a sharp departure from that logic. At trial, jurors were told they did not need to find evidence that she intended to commit the underlying felony of leaving Ariya in her car — or even knew it was happening — in order to convict her of third-degree felony murder.

“This really takes tragic accidents and elevates them to murder offenses,” Caitlin Glass, a Boston University School of Law instructor who co-authored an amicus brief in support of Jewell, told HuffPost.

Christine Monta of the MacArthur Justice Center, one of the lawyers representing Jewell on appeal, said in a statement: “Tragic accidents are not the equivalent of murder, and the court rightly recognized that Ms Jewell should not be criminally punished for an act that the State of Florida did not – and cannot – prove was knowingly and consciously done.”

The case is one of a small number nationally in which an adult who accidentally left a child in a hot car has faced felony murder charges. More than 650 children in the United States have died after being accidentally left in hot vehicles since 1990, when the rise of airbags prompted parents and caregivers to put young children in the back seat, according to Kids and Car Safety, a national nonprofit that tracks the deaths. Amber Rollins, the group’s executive director, told HuffPost she was aware of fewer than 10 cases in which a felony murder charge followed such a death.

The deaths, the group says, typically follow a familiar pattern: the caregiver is stressed, exhausted, distracted or navigating a change in routine, and the child is asleep and out of view in a rear-facing seat.

Jewell, who was close friends with Ariya’s family, has described the lasting weight of the loss. “I feel guilty if I laugh or smile. I just have so much guilt from that day,” she told HuffPost. “I don’t know how it happened. I just go over and replay it in my head and say, ‘what if’ or ‘why not,’ ‘Why didn’t I just – why? Why?’” She has said she has struggled with depression, panic attacks and suicidal thoughts since the baby’s death.

The appellate court’s reversal sends the case back to the trial court. Brian Kramer, the Baker county state attorney whose office handled the prosecution, deferred comment to the Florida attorney general’s office, which did not respond to a request for comment. An attorney representing Ariya’s family in a civil suit did not respond to a request for comment.