A Florida state appeals court has overturned the murder conviction of a woman who accidentally left a baby in her car, resulting in the child’s death.
In July 2023, while babysitting four children from two different families, Rhonda Jewell, 46, forgot that 10-month-old Ariya Paige was in the back of her car and went inside to look after the other children. Strapped to her car seat in the Florida summer heat, Ariya died of hyperthermia before Jewell realized her mistake. Jewell was convicted the following year of third-degree murder, based on the underlying crime of leaving a child unattended in a vehicle. She was sentenced to 17 years in prison.
On Wednesday, Florida’s First District Court of Appeal overturned Jewell’s convictions for third-degree murder and leaving a child unattended in a vehicle, finding that both required Jewell knowingly left Ariya in the car.
The charges against Jewell represented an attempt to significantly expand the doctrine of felony murder, a radical legal theory in which anyone involved in a crime resulting in death can be held criminally responsible for that death. Nearly every state, as well as the federal government, has some form of felony murder rule. These laws led to shocking results: women were convicted of murders committed by their attackers, the friends of a 19-year-old boy killed by law enforcement were charged in his death, and a man was held responsible for a fatal accident that occurred while he was handcuffed in the back of a police car miles away.
Defenders of the felony murder doctrine argue that even if an individual did not intend to kill anyone, because they made a choice to commit a crime that resulted in death, they should be held responsible for the harm that resulted. But Jewell’s case departs radically from this logic. At trial, jurors were told they did not need to find evidence that she intended to commit the underlying crime of leaving Ariya in her car — or even that she knew it was happening — in order to convict her of third-degree murder. In fact, jurors acquitted Jewell of aggravated manslaughter, the only charge they faced requiring a finding that Jewell acted in a way that showed reckless disregard for the baby’s life.
“It really takes tragic accidents and elevates them to the level of murder,” Caitlin Glass, a professor at Boston University Law School who co-wrote an amicus brief in support of Jewell, told HuffPost.
In the United States, more than 650 children have died after being accidentally left in hot cars since 1990, when the rise of airbags prompted parents and caregivers to place young children in the back seat, according to Kids and Car Safety. Deaths follow a familiar pattern: the parent or caregiver is usually stressed, exhausted, distracted, or facing a change in routine. The baby is asleep and out of sight in a rear-facing car seat in the back seat of the car.
Whether these deaths are treated as tragic accidents or punished as crimes is remarkably arbitrary – but it is extremely rare for prosecutors to bring murder charges in such cases. Amber Rollins, executive director of Kids and Car Safety, told HuffPost that she is aware of fewer than 10 cases in which the responsible adult was charged with murder after accidentally leaving a child in a car.
Jewell, who was a close family friend of Ariya, suffered depression, panic attacks and suicidal thoughts after the baby’s death. “I feel guilty if I laugh or smile. I feel so guilty about that day,” she told HuffPost. “I don’t know how it happened. I just go back and replay it in my head and say, ‘What if’ or ‘why not,’ ‘Why didn’t I just…why?’ For what ?”
Florida’s First District Court of Appeal on Wednesday appeared to reject the appeal of murder charges for accidental killing in a hot car. “Third-degree murder cannot be based on an unenumerated underlying crime that requires no proof of intent,” the court wrote in its opinion. “This case highlights how flawed our criminal justice system is in adjudicating accidental death. There are no winners here; the moral outrage is not assuaged. And behind the tragedy, the issues are legally significant.”
Christine Monta of the MacArthur Justice Center, one of the attorneys 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 has not — and cannot — prove was committed knowingly and knowingly.”
The appeals court requested that the case be sent back to the trial court for a new trial. Brian Kramer, Baker County prosecutor, reached out to the 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.
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