Baby Died After Being Left Unattended for 15 Minutes

In C.F. v. Pennsylvania Dep't. of Pub. Welfare, 804 A.2d 755 (Pa. Cmwlth. 2002) the mother had a ten-month-old child whom she left unattended in a bunk bed for fifteen minutes while she went downstairs to prepare the child's bottle. Upon returning to the bedroom, the child was stuck with his head between the edge of the mattress and the bed frame of a bunk bed, and was later pronounced dead. Subsequently, an indicated report of child abuse was filed against the mother. After the mother's indicated report was expunged, the Secretary of the Department of Public Welfare, Bureau of Hearings and Appeals (DPW) set aside the expungement. On appeal, we directed our attention to the criminal negligence standard in determining if this accident was non-accidental. The Court held that the mother's action did not meet the definition of child abuse because that definition only targets non-accidental events.