Commonwealth v. Huggins

575 Pa. 395, 836 A.2d 862 (2003)

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Nature of the Case

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Facts

Huggins (D) was driving a Ford van. D fell asleep. D awoke just before the van collided with the rear end of a car driven by Bayly. There were twenty-four occupants in the van. Two of the children were killed in the crash, and numerous others were taken to various hospitals with injuries. The van had only fifteen passenger seats, some of the twenty-three passengers were crowded into seats while others were seated on the floor. None of the passengers was restrained by a seatbelt and D's approximate speed was at least seventy-eight m.p.h.in a fifty-five m.p.h. zone. D was charged with aggravated assault, two counts of involuntary manslaughter, two counts of homicide by vehicle, twenty-three counts of recklessly endangering another person, and various driving offenses. D filed a pretrial motion for a grant habeas corpus relief and to dismiss the charges of aggravated assault, involuntary manslaughter, reckless endangerment, and homicide by vehicle because the Commonwealth had failed to establish a prima facie case. The trial court granted the motion to suppress evidence regarding seat belts, holding that any such evidence was barred by 75 Pa.C.S. § 4581(f). It held that P had met its prima facie burden for the charges of homicide by vehicle, but dismissed the charges of aggravated assault, involuntary manslaughter, and reckless endangerment. On the involuntary manslaughter charges; the trial court held that P had failed to make out a prima facie case for the mens rea necessary to support such a charge. P appealed. The Superior Court affirmed in part and reversed in part. It reversed the seatbelts but affirmed the dismissal of the involuntary manslaughter charges. The majority recognized that the involuntary manslaughter statute appears to set forth disjunctive bases for establishing the mental state necessary for conviction -- i.e., recklessness or gross negligence. P appealed.