A Florida state appeals court has overturned the felony murder conviction of a woman whose oversight led to the tragic death of a baby left in her car.
In July 2023, 46-year-old Rhonda Jewell was babysitting four children from two families when she inadvertently forgot that 10-month-old Ariya Paige was in the back of her vehicle. Jewell went inside to attend to the other children, leaving Ariya strapped in her car seat during the sweltering Florida summer. Tragically, the baby succumbed to hyperthermia before Jewell realized her error. In the following year, Jewell was found guilty of third-degree felony murder, based on the charge of leaving a child unattended in a vehicle, and was sentenced to 17 years in prison.
On Wednesday, Florida’s First District Court of Appeal vacated Jewell’s convictions for both third-degree felony murder and leaving a child unattended in a vehicle. The court determined that both charges necessitated proof that Jewell had knowingly left Ariya in the car.
The legal action against Jewell illustrated an attempt to broaden the application of the felony murder rule, which asserts that any participant in a felony that results in death can be held criminally liable. This legal principle exists in various forms across nearly all states and at the federal level. Such statutes can lead to controversial outcomes, including cases where women are convicted for murders perpetrated by their abusers, and individuals are held accountable for deaths that occurred while they were not directly involved.
Proponents of the felony murder doctrine argue that individuals should be held responsible for deaths resulting from their felonious actions, even if there was no intent to kill. However, Jewell’s case diverged from this rationale. During her trial, jurors were instructed that they did not need to establish that she intended to commit the offense of leaving Ariya in the car, nor that she was even aware it was occurring, to convict her of third-degree felony murder. In fact, the jury acquitted Jewell of aggravated manslaughter, the only charge requiring evidence of reckless disregard for the child’s life.
Caitlin Glass, an instructor at Boston University School of Law and co-author of an amicus brief supporting Jewell, expressed concern that such cases elevate tragic accidents to the level of murder charges.
According to Kids and Car Safety, over 650 children in the United States have died from being accidentally left in hot vehicles since 1990, a trend exacerbated by the increased use of rear-facing car seats. These incidents commonly occur when caregivers are stressed, distracted, or adjusting to changes in routine, often with the child asleep and out of sight.
Whether these deaths are classified as unfortunate accidents or criminal acts is often inconsistent, and it is quite rare for prosecutors to pursue felony murder charges in such situations. Amber Rollins, the executive director of Kids and Car Safety, indicated that she was aware of fewer than ten instances where adults faced felony murder charges after inadvertently leaving a child in a car.
Jewell, who shared a close relationship with Ariya’s family, has faced significant emotional distress following the child’s death, struggling with feelings of guilt and depression. She expressed her ongoing anguish, saying, “I feel guilty if I laugh or smile. I just have so much guilt from that day. I don’t know how it happened. I just replay it in my head and ask, ‘what if’ or ‘why not’.”
The appellate court’s ruling on Wednesday suggested a disapproval of applying felony murder charges to accidental deaths in hot cars. The court stated, “Third-degree felony murder cannot be based on an unenumerated predicate felony that does not require any proof of intent.” It further commented on the inadequacies of the criminal justice system in handling accidental deaths, emphasizing that there are no real winners in such tragic circumstances.
Christine Monta of the MacArthur Justice Center, representing Jewell on appeal, affirmed that tragic accidents should not be conflated with murder, and the court appropriately ruled that Jewell should not face criminal consequences for actions that the state could not prove were intentional.
The court has mandated that the case be returned to the trial court for a new trial. Brian Kramer, a state attorney from Baker County, referred inquiries to the attorney general’s office, which has not yet commented. An attorney for Ariya’s family involved in a civil suit also did not respond to requests for comment.
