Focal peliosis hepatis seen incidentally in five children succumbing to an asphyxiating death is described. The patients include four females and one male, with age range from 10 months to 15 years. Autopsy liver findings include speckled yellow foci to large (multiple centimeters) yellow tumor-like tissue, which fade upon standing. Microscopically, the lesions are composed of multiple cystic lacunae, which appear to be dilated hepatic sinusoids, lined by reticulin fibers, Kupffer cells, and hepatocytes. Immunohistochemical stains for factor VIII-related antigen and Ulex europaeus are negative. The lesion may represent an early form of peliosis; the possibility of interstitial/sinusoidal air cannot be ruled out.