Commonwealth v. Pedota, 64 A.3d 634

Appellant Pedota was convicted in Northampton County after a nonjury trial of Homicide by Vehicle, Involuntary Manslaughter, Driving on Roadways Laned for Traffic, and Careless Driving for a crash on I-78 that killed Mario Chacon.
Stipulated facts showed Pedota fell asleep or blacked out at the time of the collision; the logbook and accident record supported this sequence of events.
The trial court relied on the common-law and statutory framework that a driver who falls asleep can be deemed to have engaged in a volitional act of recklessness or gross negligence, satisfying mens rea for the charged offenses.
Appellant argued the terms 'falling asleep' and 'blacking out' are distinct, and that the stipulation allowed for an unknown reason for unconsciousness, which could undermine proof of mens rea beyond a reasonable doubt.
The Commonwealth argued it could rely on common knowledge of sleep’s warning signs and that the burden shifts to the driver to raise any signs; evidence could be circumstantial and still sustain a conviction.
On appeal, the Superior Court affirmed, holding that the stipulation and the circumstances supported a finding of gross negligence or recklessness and rejected Appellant’s burden-shifting and evidentiary objections.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Is the evidence sufficient to prove recklessness/gross negligence under 3732(a) and 2504(a)?	Pedota fell asleep or blacked out; sleeping driver suffices for recklessness.	Fall asleep vs. black out may be indistinct; burden to prove warning signs and voluntary act lies with Commonwealth.	Yes; evidence supported recklessness/gross negligence beyond a reasonable doubt.
Did the trial court impermissibly shift the burden by requiring the defense to prove the absence of warning signs?	Commonwealth may rely on signs; defense bears limited burden to rebut.	Burden to prove absence of warning signs rests with defendant in unusual cases.	No; burden appropriately placed and evidence supported guilt.
Does the stipulation equate falling asleep with blacking out, and does that affect mens rea?	Stipulation includes both possibilities; could negate proof of mens rea if they are equally likely.	Stipulation, read in context, shows Appellant admitted falling asleep; distinction is illusory.	Stipulation read as Appellant admitting sleep; supports requisite mental state.

Commonwealth v. Lamonda, 52 A.3d 365 (Pa. Super. 2012) (court discusses sufficiency and evidence review standards)
Commonwealth v. Huggins, 836 A.2d 862 (Pa. 2003) (sleep at wheel can establish prima facie negligence/recklessness)
Bemosky v. Greff, 38 A.2d 35 (Pa. 1944) (sleep at wheel presumed negligent; warning signs presumed)
Commonwealth v. Brewer, 876 A.2d 1029 (Pa. Super. 2005) (circumstantial evidence permitted to prove elements beyond reasonable doubt)
Commonwealth v. DiStefano, 782 A.2d 574 (Pa. Super. 2001) (standard of review for sufficiency; reliance on light favorable to Commonwealth)
Commonwealth v. Widmer, 560 Pa. 308 (2000) (sufficiency review framework for criminal convictions)
Commonwealth v. Aguado, 760 A.2d 1181 (Pa. Super. 2000) (elements of crime may be proven by circumstantial evidence)