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
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
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
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
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.