11th Circuit Upholds Daycare Director's Conviction for Failing to Report Abuse

The 11th Circuit unanimously affirmed the conviction of Latona Lambert, the former director of a Georgia Air Force base daycare, after she failed to report alleged abuse of two-year-old children. Prosecutors argued that Lambert should have acted on reports from employee Bretta Goins, who described profanity-laden music, verbal abuse, and a fear that "something was going to happen" in the toddler room. Video evidence presented at trial showed teachers Zhanay Flynn and Antanesha Fritz physically harming children and causing signs of psychological distress.

Chief Judge William Pryor wrote that a reasonable juror could infer Lambert's knowledge or deliberate ignorance, given her access to classroom monitors. The decision provides the inaugural circuit-level reading of the Victims of Child Abuse Act, emphasizing that mandatory reporters must act whenever they have a reason to suspect abuse, including mental injury.