Sep 03, 2025 in News Legal News

Legal News: Heatstroke and Dehydration at Summer Camps and Daycare: Who’s Responsible

Legal insights on child safety, heatstroke, dehydration and daycare responsibility in Canada

Every summer, families across Canada send their kids to daycares and summer camps, trusting that they’ll be safe, well cared for, and have a great time outdoors. But as heatwaves become more common, that trust is sometimes put to the test.

In recent years, there have been troubling reports of children becoming seriously ill from heat-related conditions like dehydration and heatstroke—often because proper precautions weren’t taken. These situations can lead to lasting health impacts for the child and leave families dealing with emotional stress and unexpected medical costs.

As stated in the Government of Canada Health Infobase, the Canadian Hospitals Injury Reporting and Prevention Program (CHIRPP) reported multiple cases of heat-related illness among children that were directly tied to summer camp activities between 2011 and early 2023. Among the 734 pediatric cases of sun and heat-related injuries reported during that period, 5 cases (3.0%) were explicitly connected to “summer camp activities,” indicating that children became sick due to exertion or exposure during camp programming.

When a child suffers heat-related illness while under supervision, who’s legally responsible? And what can parents do to keep their children safe—and protect their rights—if something goes wrong?

As experienced personal injury lawyers in Toronto, we break down the legal, medical, and parental considerations you need to know about these increasingly common summertime emergencies.

Understanding the Medical Risks: Why Heatstroke and Dehydration Are So Dangerous for Children

Children are more susceptible to heat-related illnesses due to their smaller bodies and developing physiological systems. Many children are unaware of their thirst or overheating, making it even more crucial for caregivers to monitor them closely.

What Is Heatstroke?

Heatstroke is the most serious form of heat illness and is considered a medical emergency. It occurs when the body’s core temperature rises above 40°C (104°F) and is unable to cool itself through sweating. It can cause:

• Seizures
• Brain damage
• Organ failure
• Coma or death

If a child shows symptoms like confusion, flushed skin, dizziness, or vomiting, caregivers must act immediately. Delays can lead to critical illness, requiring long-term treatment or life support.

What Is Dehydration?

Dehydration occurs when the body loses more fluids than it takes in, typically through sweating, urination, and respiration. For active children playing outdoors during hot Canadian summers, the risk of heat-related illnesses increases dramatically.

Signs of dehydration in children include:

• Dry mouth and tongue
• Crying without tears
• Drowsiness or irritability
• Lack of urination
• Sunken eyes

If left untreated, dehydration can evolve into heat exhaustion and ultimately heatstroke. In both cases, timely medical intervention is crucial.

Real-Life Incident: Forgotten Child in Hot Vehicle

As reported by CBC, two-year-old Eva Ravikovich died tragically after being left inside a hot SUV outside an unlicensed daycare in Vaughan, Ontario, for approximately seven hours on a summer day in July 2013. The vehicle reached temperatures estimated at over 50°C, and Eva died of heatstroke.

The daycare owner, Olena Panfilova, initially told authorities that the child had died during a nap inside the daycare. However, it was later revealed in court that Eva had never been brought inside. Panfilova had forgotten to remove her from the car after dropping off other children, and only discovered the child in the vehicle later that afternoon.

Panfilova pleaded guilty to criminal negligence causing death, and had previously been found guilty under Ontario’s Day Nurseries Act for operating an illegal daycare with far more children than legally permitted. At the time of Eva’s death, 35 children were in her care—well above the five-child limit for unlicensed home daycares.

The case also raised concerns about government oversight. Despite previous warnings from Ministry of Education inspectors, the illegal daycare had continued operating without appropriate intervention. Eva’s family has since pursued legal action against both the daycare operators and the Ministry, alleging systemic failure to protect children from foreseeable harm.

This heartbreaking case underscores the devastating consequences of inadequate supervision and the importance of strong accountability in child care settings—especially during the summer months when heat-related risks are at their peak.

Legal Duty of Care: What Are Daycares and Summer Camps Required to Do?

In Canada, any group that takes care of children, such as summer camps, outdoor education programs, or licensed daycares, has a legal duty to do so. This means they must do everything possible to keep each child safe and healthy while in their care. If they fail to do this, the company could be sued for negligence.

What does it mean to take reasonable care?

Reasonable care includes:

• Checking the weather every day and Environment Canada's heat alerts
• Giving shaded places to rest or air-conditioned rooms indoors
• Ensure frequent water breaks and monitor the amount of fluid employees consume.
• Teaching employees how to spot the first signs of heat illness
• Adjusting or cancelling outdoor activities during heatwaves is essential.

If your child got sick from the heat at camp or daycare and these rules weren't followed, a personal injury lawyer can help you prove that someone was careless.

Learn more about how our critical illness lawyers help families recover after catastrophic injuries.

Is It a Case of Negligence or Medical Malpractice?

The legal route you take will depend on who was involved and how the injury occurred.

General Negligence

Most daycare and camp incidents involving heatstroke or dehydration fall under general negligence, meaning the supervisors failed to act as a “reasonable person” would in similar circumstances. This could include:

• Ignoring weather warnings
• Failing to ensure adequate hydration
• Providing no shaded areas during outdoor activities

In these situations, working with a personal injury attorney can help families pursue financial compensation and ensure the organization is held accountable.

Medical Malpractice

If medical professionals were involved—such as a camp nurse or on-site paramedic—and they failed to meet their professional standards, the case might qualify as medical malpractice.

For example, if a child showed obvious signs of heatstroke and medical staff failed to recognize them, gave improper treatment, or delayed emergency response, then parents may pursue a medical malpractice claim.

Learn more about our experienced medical malpractice lawyers.

What Legal Options Do Parents Have?

When tragedy strikes, parents have several legal avenues to explore:

1. File a Personal Injury Claim

If someone else's carelessness caused your child's injuries, you may be eligible for financial compensation. A personal injury lawyer Toronto who has been around for a while can help you get:

• Pain and suffering
• Costs for medical care and rehabilitation
• Emotional pain
• Need special care or are permanently disabled
• Parents lost income because they had to take care of someone.

Our team at Neinstein Personal Injury Lawyers offers free consultations and works on a "contingency fee" basis, which means you don't have to pay us unless we win your case.

2. Report to Provincial Licensing Authorities

Most provinces mandate the licensing and supervision of daycares and camps. Parents can make complaints to the Ministry of Education, public health departments, or child protection services. These groups can look into things, give out fines, or take away licenses.

3. Seek Human Rights Remedies (When Applicable)

Parents may also want to file a human rights complaint under their provincial or territorial Human Rights Code if their child's disability, religion, or other protected trait was ignored, which led to more exposure to heat or delayed care.

Trauma Season: Why Summer Poses Heightened Risk for Children

The legal and medical communities agree that summer is "trauma season." The risk of accidents and medical emergencies goes up when more kids are outside, whether they are at camps, splash pads, or daycares.

Learn more in our article on Summer Driving Accidents and Trauma Season

This danger gets worse in extreme weather. Most caregivers know how to look out for physical accidents, but many don't realize how dangerous heat exposure can be, especially for young children or people who already have health problems.

How Parents Can Protect Their Children: Questions to Ask

Prevention begins at home. Before enrolling your child in a summer program, take time to vet their safety protocols. Ask:

• Do you follow Environment Canada heat warnings?
• Are staff trained in CPR and recognizing heat illness?
• What’s the staff-to-child ratio?
• How often are children given water breaks?
• Is there an indoor or shaded space for cooling off?

Read Canada’s official Guide to Extreme Heat and Health for more prevention tips.

If the program’s answers feel vague or dismissive, it may not be the right environment for your child.

How Neinstein’s Legal Team Can Help Your Family Move Forward

As one of Toronto's most trusted personal injury law firms, Neinstein Personal Injury Lawyers knows how horrible it is when kids get hurt because of someone else's carelessness. When your child gets heatstroke or dehydration, which are both easily avoidable, it can be devastating emotionally, and the legal process can be scary to navigate.

Our experienced team of:

• Personal injury attorneys
• Critical illness lawyers
• Medical malpractice lawyers

We work tirelessly to ensure that negligent parties are held accountable and that your family receives the full compensation you deserve to support recovery and rehabilitation.

Final Thoughts: Seeking Justice After Preventable Summer Tragedies

Summer is meant to be a time for kids to explore, play, and make lasting memories—not end up in the hospital because of something that could have been prevented. Sadly, heat-related illnesses like dehydration and heatstroke still happen far too often, and many are the result of poor planning or negligence by those responsible for keeping children safe.

When caregivers fail in their duty, families are left to pick up the pieces. Seeking justice isn’t just about compensation—it’s about accountability and making sure no other child has to go through the same thing.

If your child has suffered due to heat-related illness at a daycare or summer camp, you don’t have to navigate it alone. Speak with a personal injury lawyer in Toronto who understands what you're going through and can help protect your family's rights.

Contact Neinstein Personal Injury Lawyers today for your free case review. We’re here to help your family rebuild—physically, emotionally, and financially.