The Iowa Supreme Court reversed a district court decision and reinstated a founded child abuse assessment against a registered childcare provider whose five-month-old charge died from anoxic brain injury after being found with her face in a blanket during naptime.
In *Amanda Cooke v. Iowa Department of Health and Human Services* (Iowa 2026), the court unanimously upheld the state's determination that childcare provider Amanda Cooke denied the infant critical care by failing to provide proper supervision required under Iowa Code section 232.68(2)(a)(4)(b).
The tragic incident occurred when the five-month-old child was placed down for a nap by Cooke, a state-registered category B childcare provider. The infant was later found with her face in a blanket and subsequently died from anoxic brain injury, a condition caused by lack of oxygen to the brain.
As a registered childcare provider, Cooke was required to comply with specific protocols, including safe sleep regulations and facility requirements. The Iowa Department of Health and Human Services (HHS) conducted an investigation and issued a founded child abuse assessment, determining that Cooke had denied the child critical care through inadequate supervision.
Under Iowa law, proper supervision is defined as "the supervision that a reasonable and prudent person would exercise under similar facts and circumstances." HHS applied this standard in concluding that Cooke's level of care fell below what would be expected of a reasonable and prudent person in her position.
Cooke challenged the founded assessment through judicial review in the Iowa District Court for Polk County. Judge Jeanie K. Vaudt reversed the HHS determination, interpreting the "reasonable and prudent person" standard as an objective "generic person" test that does not consider the specific training or knowledge of the individual caregiver.
The district court remanded the case to HHS with instructions to reconsider the assessment under this revised interpretation of the standard. The lower court's ruling suggested that Cooke's specialized training and knowledge as a registered childcare provider should not factor into the evaluation of whether her supervision met the statutory requirement.
HHS appealed the district court's decision to the Iowa Supreme Court, arguing that its original application of Iowa law was correct. The state maintained that the founded child abuse assessment was properly issued based on Cooke's failure to provide adequate supervision that resulted in the infant's death.
In a unanimous opinion delivered by Justice Oxley, the Iowa Supreme Court sided with HHS and reversed the district court's ruling. The high court agreed with the department's application of Iowa law in finding that Cooke denied the child critical care under the statutory provision.
The court's decision effectively reinstates the founded child abuse assessment against Cooke. The ruling clarifies the application of the "reasonable and prudent person" standard in cases involving licensed or registered childcare providers who are subject to specific training requirements and safety protocols.
The case highlights the critical importance of proper supervision in childcare settings, particularly regarding safe sleep practices for infants. Safe sleep guidelines typically require that infants be placed on their backs to sleep, in cribs free of blankets, pillows, and other soft bedding that could pose suffocation risks.
The death of the five-month-old represents a devastating outcome that underscores the responsibilities placed on registered childcare providers. Category B registered providers in Iowa must meet specific qualifications and follow established safety protocols designed to protect children in their care.
The Iowa Supreme Court's reversal of the district court decision reinforces the state's authority to hold childcare providers accountable when their supervision falls below statutory standards. The ruling supports HHS's position that registered providers can be subject to founded child abuse assessments when their care results in harm to children.
The case was argued by Assistant Attorney General Tabitha J. Gardner for HHS, while Eric S. Mail and Eric D. Puryear of Puryear Law represented Cooke. Attorney General Brenna Bird also participated in the state's representation.
The decision carries implications for childcare providers throughout Iowa, clarifying that the reasonable and prudent person standard applies to their supervision responsibilities. The ruling emphasizes that registered providers who fail to meet statutory supervision requirements may face founded child abuse assessments when their inadequate care contributes to harm.
The reinstatement of the founded assessment against Cooke serves as a reminder of the serious legal consequences that can result from inadequate supervision in childcare settings, particularly when such failures contribute to tragic outcomes like the death of a child in care.