[22] In Regina v. Simons, [2018] A.J. No. 598 (P.C.), a caregiver left a child in a closet in a car seat for 5 hours while she went shopping. The child was asphyxiated by the harness after sliding down in the seat. The accused concealed the circumstances of death for several months and was sentenced to 3 ½ years in custody.
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