Wake County District Attorney Colon Willoughby said it does not appear Tim Day intentionally left the toddler in the van.
"It simply seems to be an oversight rather than an knowingly, intentional, willful act on Day's part," he said.
Day, a volunteer at the Corinth United Church of Christ, told investigators he forgot about the little girl.
An autopsy report shows Clifton died from heatstroke. Investigators said the temperature in the van was over 100 degrees.
Clifton's family said they do not fault Day in the incident. They said the day care should have had a system in place like an attendance sheet or roster list to make sure all of the children were accounted for.
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