The hearing heard how Charlie was found unresponsive in the bath when police were called by paramedics to a house in West Chilton Terrace, Chilton, on 16 February 2022.
He was airlifted to the Royal Victoria Infirmary in Newcastle, but died shortly after arrival.
Martin Sharpe, defending, told the court Massey accepted it was “her fault the seat was not properly affixed to the bath”.
“She should have affixed it to a flat bath, hers is concave, the suction pad wouldn’t properly work,” Mr Sharpe said.
“This caused her child to tip over and then drown.”
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