Commonwealth v. Root
403 Pa. 571, 170 A.2d 310 (1961)
- Root and another guy agreed to drag race. They took off down the road, driving recklessly. Root won the race when the other guy crashed into a truck head-on and died.
- Root was arrested and charged with involuntary manslaughter.
- The Trial Court convicted Root of involuntary manslaughter. He appealed.
- The Trial Court found that Root was acting recklessly, and that recklessness resulted in the death of another person.
- The Pennsylvania Supreme Court overturned the conviction.
- The Pennsylvania Supreme Court found that there are two elements to involuntary manslaughter:
- The defendant must act recklessly.
- The defendant’s actions must be the direct cause of the death.
- Aka causation.
- In this case, the Court found that Root was acting recklessly (and was therefore guilty of speeding et. al.), but that he didn’t directly the other guy’s death. That happened because the other guy recklessly drove into oncoming traffic.
- Basically, Root was driving like a maniac and if he had crashed into a car and killed someone he would certainly be guilty. But he isn’t criminally culpable for the other guy’s bad driving, even if they were involved in the same unlawful activity.
- The Court found that the standard should be whether there was a direct causal connection between Root’s actions and the death, not just whether there was a proximate cause.
- The Court found that proximate cause is for civil (tort) liability, but for criminal liability the standard should be higher.
- Conversely, the court in State v. McFadden (320 N.E.2d 608 (1982)) found that proximate cause was the proper standard.
- In a dissent it was argued that the crash was a reasonably foreseeable consequence of Root’s reckless actions, and therefore he should be held criminally culpable.
- If the innocent truck driver the other guy crashed into had died, then it is likely that Root would have been criminally culpable for that death.
- See McFadden.