Com. v. Kralovic, M., 1562 WDA 2016

On June 23, 2012, after a night of drinking, three 18‑year‑olds (Kralovic, Lysell, and Vrudney) drove toward Kralovic’s house by different routes to “see who would arrive first.”
Kralovic (Appellant) drove a Lincoln at ~85 mph in a 45 mph zone, lost control on a curve, flipped and came to rest blocking the eastbound lane; his BAC measured 0.135% within two hours.
Lysell (passenger) exited into the roadway when the car overturned; Kralovic exited to safety at the roadside.
Vrudney, driving a pickup at ~78 mph with BAC 0.154%, approached, sideswiped the overturned Lincoln and struck Lysell standing in the westbound lane; Lysell died of severe head injuries.
Kralovic was convicted by jury of homicide by vehicle while DUI, involuntary manslaughter, recklessly endangering another person, multiple DUI counts, and traffic offenses; sentenced to 3–6 years (with other concurrent penalties). He appealed arguing insufficiency of causation and exclusion of character evidence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency: Was Kralovic’s DUI a direct and substantial cause of Lysell’s death?	Commonwealth: Kralovic’s reckless DUI driving initiated the chain of events that placed Lysell in the roadway and in danger, satisfying direct causation.	Kralovic: Vrudney was the immediate cause of death; Kralovic’s crash was a separate incident and any racing/causation was not proven; passenger’s own conduct and co‑driver’s actions intervened.	Affirmed. Viewing evidence favorably to Commonwealth, Kralovic’s reckless DUI was an operative cause and foreseeable, so convictions were supported.
Evidentiary: Did the trial court err by excluding the victim mother’s testimony as character evidence for Kralovic?	Kralovic: Mother could testify to his reputation for safe driving (not a family member) and rebut inference of dangerous propensity.	Commonwealth/Trial Ct: Testimony inadmissible or unreliable; trial court exercised discretion.	Any error harmless. Overwhelming evidence of guilt made exclusion non‑prejudicial.

Commonwealth v. Moyer, 171 A.3d 849 (Pa. Super. Ct.) (sufficiency standard on appeal)
Commonwealth v. Tanner, 61 A.3d 1043 (Pa. Super. Ct.) (elements of homicide by vehicle while DUI)
Commonwealth v. Fabian, 60 A.3d 146 (Pa. Super. Ct.) (involuntary manslaughter causation and mental state)
Commonwealth v. Rementer, 598 A.2d 1300 (Pa. Super. Ct.) (two‑part test for direct and substantial criminal causation)
Alleyne v. United States, 133 S.Ct. 2151 (U.S. 2013) (impact of mandatory minimum statutes on sentencing procedures)