Commonwealth v. Wyatt
203 A.3d 1115
| Pa. Super. Ct. | 2019Background
- On June 3, 2015, Franklin Dale Wyatt’s southbound tractor-trailer crossed the median on I-380 and struck a northbound tractor-trailer and passenger bus, causing three deaths and multiple serious injuries.
- Commonwealth charged Wyatt with multiple counts including aggravated assault by vehicle, homicide by vehicle, involuntary manslaughter, recklessly endangering another person, and various traffic offenses.
- Wyatt filed a pretrial writ of habeas corpus arguing the Commonwealth lacked prima facie evidence of the required mens rea (recklessness/gross negligence) for most counts.
- At the habeas hearing the Commonwealth relied on a CARS reconstruction report (ruled out speed, weather, mechanical failure; could not rule out distraction), GPS data showing normal speeds, phone records showing Wyatt received texts while driving, and evidence of two unrestrained dogs and food/beverages in the cab.
- Trooper Waters testified there was no evidence Wyatt looked at his phone, no skid marks or erratic driving, and no proof that dogs, food, or other factors distracted Wyatt; blacking out was a possible non-criminal explanation.
- Trial court granted the habeas petition; Superior Court affirmed, holding the Commonwealth’s proof was speculative and insufficient to establish recklessness at the prima facie stage.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Commonwealth presented prima facie evidence of recklessness/gross negligence for vehicle homicide and related charges | Commonwealth: elimination of non-criminal causes (weather, mechanical issues, speed) plus circumstantial indicators (texts, unrestrained dogs, items in cab) permits inference of distracted driving and thus recklessness | Wyatt: evidence only shows negligence/carelessness or an unexplained accident; no proof he consciously disregarded a substantial, unjustifiable risk (no proof he looked at phone or was distracted) | Court: Affirmed habeas relief — evidence speculative; Commonwealth failed to meet prima facie burden to show recklessness |
Key Cases Cited
- Dantzler v. Commonwealth, 135 A.3d 1109 (Pa. Super. 2016) (standard for reviewing pretrial habeas corpus and prima facie burden)
- Karetny v. Commonwealth, 880 A.2d 505 (Pa. 2005) (scope and de novo review for sufficiency of prima facie case)
- Huggins v. Commonwealth, 836 A.2d 862 (Pa. 2003) (recklessness and gross negligence as equivalent mental states)
- Karner v. Commonwealth, 193 A.3d 986 (Pa. Super. 2018) (Commonwealth failed to produce evidence of recklessness at preliminary hearing in vehicular homicide context)
- Bongiorno v. Commonwealth, 905 A.2d 998 (Pa. Super. 2006) (appellate responsibility for complete record transmission)