Commonwealth v. Huggins

Facts

Defendant drove van and crashed as a result of falling asleep at the wheel.  Two children were killed in the accident.

History

Case dismissed at trial and appellate level.

Issue

Does allowing oneself to knowingly falling asleep at the wheel meet the intent required for a prima facie involuntary manslaughter case?

Holding/Rule

Yes.  Reversed and remanded.  A prima facie case exists where the prosecution produces evidence as to each element of the crime.  The evidence must only be sufficient enough for a judge to warrant the case going to a jury.  The immediate statute requires that the defendant be grossly negligent.  To create the prima facie case, prosecution must show defendant “disregarded a substantial and unjustifiable risk that the direct result of his behavior would be the death of one or more of his passengers or another person on the highway.”

Analysis

To create a prima facie case for involuntary manslaughter the prosecution must only show that defendant acted recklessly or with criminal negligence.  The prosecution presents evidence that falling asleep at the wheel of a car can be negligent itself; but in the instant case, an additional level of recklessness exists where a driver allows himself to fall asleep with a fan packed with 21 children.  Driving is an inherently dangerous, highly regulated activity.  As a licensed driver, defendant was aware of the risks associated with driving responsibility.  Drivers have a duty to remain conscious or desist from driving.  The argument that defendant was unaware or could not be warned that he was falling asleep is unpersuasive.  Reasonable people, ordinary drivers are fully capable of noticing signs of fatigue within themselves, absent a diagnosable disorder.

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