Commonwealth v. Root

Brief Fact Summary. The Defendant, Root (Defendant), was found guilty of involuntary manslaughter for the death of man against whom he was competing in a car race on a highway. The decedent was killed when he swerved into a lane of oncoming traffic in order to pass Defendant’s car.

Synopsis of Rule of Law. The crime of involuntary manslaughter requires both reckless conduct on the part of the defendant and that that recklessness was the direct cause of the resulting death.

Facts. Defendant accepted decedent’s challenge to a drag race on a nearby highway. During the course of a race that reached speeds well above the speed limit, decedent swerved into a lane of oncoming traffic in order to pass Defendant’s car. Decedent’s car thereupon engaged in a head-on collision with a truck that caused his death.

Issue. Is a defendant criminally liable for another’s death where both parties are engaged in life-threatening reckless conduct?

Held. No. Judgment reversed.
Though Defendant was driving recklessly at a speed far above the legal limit, decedent himself was engaged in willful recklessness by participating in the race and swerving into a lane of oncoming traffic. Decedent’s decision to race his car in a lane of oncoming traffic was the actual cause of his death – not Defendant’s own reckless driving. The action of steering his car into a lane of oncoming traffic was that of the decedent himself and was not forced upon him by Defendant.

Dissent. Decedent’s act in steering his car into a lane of oncoming traffic was a natural reaction to the environment of a “drag race” that Defendant helped create. Decedent’s action was normal under the circumstances and could reasonably have been foreseen by the Defendant.

Discussion. The majority in this case is principally concerned with the fact that decedent’s decision to enter the race and his decision to steer into oncoming traffic were both made of his own volition.