Rochelle Sapp, a home daycare business owner in Iowa, is accused of throwing a toddler to the ground for failing to remove her coat last month.
The three year-old, Autumn Elgersma, died from her injuries.
On October 29, Sapp phoned Elgersma's mother to tell her that her daughter had injured her head during a fall at the Orange City, Iowa, residence.
She said the three-year-old had fallen down some stairs.
Two days later, Elgersma died in Sioux Falls, S.D., children's hospital while receiving treatment her for a skull fracture and brain swelling, reports indicate.
Doctors said the injuries were inconsistent with a child falling down stairs, and police allege that Sapp, 33, later admitted throwing the girl to the ground.