Commonwealth v. Root case brief (191 Pa. Superior Ct. 238)

Commonwealth v. Root

191 Pa. Superior Ct. 238 (1959)

FACTS
-Defendant, Root, accepted the deceased's challenge to an auto race.
-While the two were racing at high rates of speed, which were well over the legal speed limit, the deceased went on the wrong side of the road in an attempt to pass the defendant and D got in an head-on collision with a truck.

PROCEDURAL HISTORY
Trial court: the defendant was held directly responsible for the death of the deceased.

Issue: Was the defendant the direct cause of the death of the deceased?

Holding: No, Reversed.

ANALYSIS
-Deceased voluntarily decided to race the defendant and he voluntarily drove on the wrong side of the road in order to beat the defendant. The defendant did not force these actions upon the deceased.-Deceased's death was the result of his own reckless actions. 
-Hall was reckless, but his recklessness is no defense to the criminal responsibility of the defendant for the natural and probable consequences of his recklessness.
-The conduct of all parties involved, including the deceased, and all conditions which might contribute to the death, must be considered in determining whether the unlawful act of the defendant was a proximate cause of the death.

Dissent: It was the defendant whose reckless actions caused the deceased to drive on the wrong side of the road. It was foreseeable to the defendant that his actions could result in death or serious injury and the fact that he still chose to race makes him guilty of the death of the deceased.

Link to Case:  Commonwealth v. Root (full case)