My kids both spent a lot of time sleeping in their bouncy chairs or swings. They wouldn't sleep laying flat, and they both had reflux. Laying them flat on their backs was not practical.

That poor mother.. the baby was only in that car seat for an hour. It's horrible to say, but it's very possible that baby would have passed on with or without the car seat.

I'm not negating the danger of sleeping in a seated position, just saying that if that baby died after one hour in that position, after an entire night of back sleeping, then maybe I just shouldn't take my kids in the car until they're six months old.