sacramento county sheriff's department
Angela Phakhin, 27, and her boyfriend Untwan Smith, 46, arrested on Wednesday after being charged with child endangerment and conspiracy in Rancho Cordova, California. Sacramento County Sheriff's Department

A woman and her boyfriend, reportedly living out of their SUV, were arrested in Rancho Cordova, California after the woman’s 3-year-old daughter was found dead in the car, CBS-affiliate KOVR reported Wednesday.

Authorities found the girl on Wednesday because the couple’s Toyota Rav-4 was parked the wrong way. The girl’s biological mother, 27-year-old Angela Phakhin, and her boyfriend 46-year-old Untwan Smith, were arrested after police discovered Smith had an outstanding warrant in Arkansas.

When police searched his car, they found the Phakhin’s 3-year-old daughter wrapped in blankets. A Sacramento County Sheriff press release described her as “unresponsive.” She was pronounced dead at the scene.

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“There were no obvious signs of trauma, so they’re still in the beginning stages of this death investigation. These child cases aren’t as cut and dry as other death investigation cases,” Sacramento County Sheriff Sgt. Tony Turnbull said.

He continued, “Usually, it takes an autopsy, cause and manner of death to be determined by the coroner, along with the investigation and working with the district attorney before decisions can be made whether there are criminal charges to be found.”

Authorities stated they believe the couple arrived in California in February 2017. According to a statement released by investigators, they believe child endangerment may have had a role in the girl’s death.

California Penal Code 273a PC listed child endangerment as a California domestic violence, according to Shouse California Law Group. For someone to be accused of child endangerment in the state of California, they must have caused or permitted a child to suffer unjustifiable physical pain or mental suffering; willfully caused or permitted a child in their care to be injured or willfully caused or permitted a child to be placed in a dangerous situation.

California placed an emphasis on being “criminally negligent” in their definition of child endangerment. Unlike with the crime of child abuse, in the state of California, a person can be convicted of child endangerment even if the child was not injured. However, that was not the case with Phakhin’s daughter — the child endangerment charge is stronger because the girl died.

The couple was questioned by detectives at the Sacramento County Child Abuse Bureau and the Coroner. Phakhin and her boyfriend were charged with child endangerment and conspiracy. Their bail was set at $1,000,000 each and they will be arraigned on Friday in Sacramento Superior Court.

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According to a fact sheet by the National Center for Fatality Review and Prevention (CFRP), more than 1,700 children in the United States die of child abuse and neglect yearly. Children under the age of four comprised 81.6% of these deaths. The report also stated that when fatalities occur, a combination of poverty, domestic violence and substance abuse are commonly responsible.

“Fatal child abuse may involve repeated abuse over a period of time, or it may involve a single, impulsive incident,” said a 2015 study conducted by the Child Welfare Information Gateway. “In cases of fatal neglect, the child’s death results not from anything the caregiver does; rather, it results from a caregiver’s failure to act.”