John Edward Hardin v. Commonwealth of Virginia, 1246162

On June 7, 2015, John Edward Hardin was driving an 18‑wheel tractor‑trailer on Route 1 at night when his truck struck and killed cyclist Kristina Goodrow riding on the right shoulder.
The roadway was unlit, speed limit 45 mph; the right northbound lane was ~11 feet wide, the truck front ~8 feet, and the bicycle handlebars just over 2 feet.
Hardin told officers at the scene he first saw what he thought was a bicyclist "four to five hundred feet" away, had his bright lights on, and attempted to move left but thought vehicles occupied the left lane.
Video and a civilian witness (driving behind Hardin) contradicted aspects of Hardin’s later testimony; the witness said he did not see Hardin brake, honk, or change lanes before the collision.
Officer measured the distance from the impact to where Hardin stopped at 408.9 feet; the trial court credited Hardin’s initial statement that he first saw the bicyclist 400–500 feet away and found him guilty of involuntary manslaughter for criminal negligence.

Issue	Plaintiff's Argument (Commonwealth)	Defendant's Argument (Hardin)	Held
Whether the evidence sufficed to prove criminal negligence for involuntary manslaughter	Hardin saw the victim 400–500 ft away, had time and distance to avoid collision, and failed to take evasive action, showing reckless disregard	Hardin argued his later statements and trial testimony show he saw the bicyclist only 150–180 ft away and had no time to react; his initial statement cannot alone sustain conviction	Court affirmed: factfinder credited initial statement and found sufficient evidence of criminal negligence
Whether the extrajudicial statement that he first saw the bicyclist 400–500 ft away was an uncorroborated confession that cannot support conviction	The statement was an admission against penal interest supporting guilt and did not constitute an uncorroborated confession requiring reversal	Hardin argued the statement was uncorroborated and inconsistent with other testimony and therefore insufficient	Court held the statement was an admission (not a full confession) and, when credited with other evidence (stopping distance), supported conviction

Greenway v. Commonwealth, 254 Va. 147 (definition of involuntary manslaughter as killing from negligence so gross as to show reckless disregard)
Gooden v. Commonwealth, 226 Va. 565 (criminal negligence requires unlawful performance of a lawful act so gross, wanton, and culpable as to show reckless disregard)
Jenkins v. Commonwealth, 220 Va. 104 (conviction reversed where defendant saw victim only immediately before impact)
Richardson v. Commonwealth, 192 Va. 55 (tractor‑trailer operator guilty where maneuver showed utter disregard for pedestrian safety)
Carminade v. Commonwealth, 230 Va. 505 (distinguishing confession from admission against interest)