Former federal daycare director’s failure to report conviction upheld

A federal appeals court found there were sufficient reasons for Latona Lambert to suspect children were abused by teachers at Robins Air Force Base.ATLANTA (CN) — Efforts from the former director of a Georgia Air Force base daycare center to overturn her conviction for failing to report suspected child abuse were rejected by an 11th Circuit panel Tuesday.Latona Lambert was sentenced to two years of probation in February 2025 after two teachers, Zhanay Flynn and Antanesha Fritz, pleaded guilty to child cruelty for their treatment of 2-year-olds in their care.She argued the government failed to prove beyond a reasonable doubt she knew of children being abused in one of the 16 classrooms at Childs Development Centers on Robins Air Force Base.“Because Lambert had reason to suspect the abusers were subjecting children to mental injury, we affirm her conviction,” Chief U.S. Circuit Judge William Pryor wrote in the unanimous opinion.The 11th Circuit is the first circuit court to interpret the provision of the Victims of Child Abuse Act that requires certain people working in federal facilities to make a timely report should they have a reason to suspect a child has suffered abuse, Pryor wrote. The law separates acts of child abuse into several categories, including physical injury and mental injury.Pryor said the act does not place a heavy burden of proof on the prosecution. He said it requires mandatory reporters to report any time he or she has a reason to suspect a child has suffered abuse.A reasonable jury could have inferred Lambert had reason to suspect the children in the toddler classroom had suffered mental injury, Pryor wrote, which is defined as harm to a child’s psychological or intellectual functioning.The director received reports from daycare worker named Bretta Goins, who told her things were not right in the classroom, that teachers were not nice to the toddlers, cursed at them, and played music fraught with profanity in their presence.Goins also expressed her fear that “something was going to happen" and refused to continue working in the classroom.“A jury could infer that a reasonable person would think that childcare workers who routinely cursed at children under their care and played profane music might have caused them mental injury,” Pryor wrote.The jury also could infer Lambert saw video footage of the children being harmed, the judges held, because she had access to video monitors of the classrooms in her office that employees testified she scoured often for evidence of minor policy violations.During trial, the jury saw a video compilation of nearly 100 incidents of Fritz and Flynn harming the children. Among other things, they hit the children, dragged them across the room, and forced them to fight each other. It also showed the children exhibiting signs of mental injury, including withdrawal and changes in behavior.Pryor wrote that if Lambert refused to watch the video because she wished to “remain in ignorance,” then the jury could reasonably infer her deliberate ignorance of the incidents captured on video was the equivalent of knowledge.According to the appeals court judges, a jury could have reasonably concluded Lambert should have investigated the toddler classroom and by claiming Goins had not reported the issues to her, could have also believed she was trying to cover up her failure to report.He was joined on the panel by U.S. Circuit Judges Jill Pryor, a Barack Obama appointee and Andrew Brasher, a Donald Trump appointee.Categories / Appeals, CriminalSubscribe to our free newslettersOur weekly newsletter Closing Arguments offers the latest about ongoing trials, major litigation and rulings in courthouses around the U.S. and the world, while the monthly Under the Lights dishes the legal dirt from Hollywood, sports, Big Tech and the arts.Additional Reads