Deputies said they arrested Penelope Stanley, 54, of Pontotoc, on three felony charges of animal cruelty.
According to an arrest report, hotel guests called 911 before 9 a.m. after hearing the puppies barking and crying in an SUV with its windows cracked open.
Deputies said Minnie, a 6-month-old Chihuahua, died, while Kiara, a 3-month-old shepherd mix, is not doing well and Gruff, a 6-month-old terrier mix, is recovering.
According to the report, Stanley told deputies she last checked on the puppies at 6:30 a.m. and that at that time, they were fine.
Kiara and Gruff are now under the care of Orange County Animal Services, the Sheriff's Office said.
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