Commonwealth v. Wyatt, 1832 EDA 2018

Decision Date07 February 2019
Docket NumberNo. 1832 EDA 2018,1832 EDA 2018
Citation203 A.3d 1115
Parties COMMONWEALTH of Pennsylvania, Appellant v. Franklin Dale WYATT, Appellee
CourtPennsylvania Superior Court

Elmer D. Christine, Jr., District Attorney, and Curtis J. Rogers, Assistant District Attorney, Stroudsburg, for Commonwealth, appellant.

Marc Neff, Philadelphia, for appellee.

BEFORE: OTT, J., DUBOW, J. and STRASSBURGER, J.*

OPINION BY STRASSBURGER, J.:

The Commonwealth of Pennsylvania appeals from the order granting Franklin Dale Wyatt's pre-trial motion for writ of habeas corpus. We affirm.

We glean the following factual and procedural history from the record. Briefly, on June 3, 2015, Wyatt was driving a tractor-trailer southbound on Interstate 380 (I-380). At approximately 10:00 a.m., Wyatt's vehicle crossed the grassy median separating the north- and southbound lanes of travel on I-380 and struck a northbound tractor-trailer and passenger bus, resulting in the deaths of three people and serious injuries to five others.

Based on the foregoing, the Commonwealth charged Wyatt with eight counts of aggravated assault by vehicle, three counts of homicide by vehicle, three counts of involuntary manslaughter, 17 counts of recklessly endangering another person, and one count each of disregarding traffic lanes, careless driving, and reckless driving.

Wyatt filed several pre-trial motions.1 Relevant to this appeal, he filed a motion for writ of habeas corpus2 as to all charges, except disregarding traffic lanes and careless driving, challenging the Commonwealth's prima facie evidence for the mens rea requirement of recklessness or gross negligence. A hearing was held on April 13, 2018. At the hearing, the Commonwealth presented the testimony of the affiant, Pennsylvania State Police Trooper Tyler Waters, along with several exhibits, to support its theory of recklessness based on distracted driving. On June 20, 2018, the trial court issued an order and opinion which, inter alia , granted Wyatt's motion for writ of habeas corpus. This timely-filed appeal followed.3

On appeal, the Commonwealth presents one question for our review: whether the Commonwealth presented sufficient evidence of recklessness or gross negligence in order to sustain its prima facie burden at the habeas corpus proceeding. Commonwealth's Brief at 4. We begin with our standard of review.

"We review a decision to grant a pre-trial petition for a writ of habeas corpus by examining the evidence and reasonable inferences derived therefrom in a light most favorable to the Commonwealth." Commonwealth v. Dantzler , 135 A.3d 1109, 1111 (Pa. Super. 2016) (en banc ) (citation omitted). Whether the Commonwealth satisfied its burden of establishing a prima facie case for each charged crime is a question of law, to which this Court's standard of review is de novo and our scope of review is plenary. See Commonwealth v. Karetny , 583 Pa. 514, 880 A.2d 505, 528 (2005).

A pre-trial habeas corpus motion is the proper means for testing whether the Commonwealth has sufficient evidence to establish a prima facie case. To demonstrate that a prima facie case exists, the Commonwealth must produce evidence of every material element of the charged offense(s) as well as the defendant's complicity therein. To meet its burden, the Commonwealth may utilize the evidence presented at the preliminary hearing and also may submit additional proof.

Dantzler , 135 A.3d at 1112 (citations and quotations marks omitted).

In his memorandum in support of his petition for a writ of habeas corpus , Wyatt contended that the Commonwealth could not establish criminal culpability and thus failed to establish the mens rea requirement for aggravated assault by vehicle, homicide by vehicle, involuntary manslaughter, recklessly endangering another person, and reckless driving. Supplemental Memorandum of Law in Support of Defendant's Motion to Dismiss and Motion for Writ of Habeas Corpus , 5/1/2018, a 12-13 (unnumbered). Because recklessness and gross negligence are equivalent states of mind for the crimes Wyatt challenged, see Commonwealth v. Huggins , 575 Pa. 395, 836 A.2d 862, 868 (2003), we refer to the mens rea requirement simply as recklessness, keeping the following in mind.

A person acts recklessly with respect to a material element of an offense when he consciously disregards a substantial and unjustifiable risk that the material element exists or will result from his conduct. The risk must be of such a nature and degree that, considering the nature and intent of the actor's conduct and the circumstances known to him, its disregard involves a gross deviation from the standard of conduct that a reasonable person would observe in the actor's situation.

Id. at 868–69 (quoting 18 Pa.C.S. § 302(b)(3) ).

On appeal, the Commonwealth maintains that it presented sufficient prima facie evidence to establish that Wyatt acted recklessly. Commonwealth's Brief at 9. Specifically, the Commonwealth cites to the lack of other contributing causes (weather, mechanical failures) and the existence of potentially distracting circumstances (receiving text messages, unrestrained dogs in the cabin) to support its contention that Wyatt was distracted, and that "such inattentiveness is, in and of itself, sufficient to demonstrate the level of recklessness sufficient to sustain the charges at a prima facie level." Id. at 13-15. Further, the Commonwealth avers that it "need not prove, in an affirmative way, the actual existence or cause of [Wyatt's] distracted driving (or put another way, inattentiveness) if circumstantial evidence supports such a conclusion at a prima facie level. The [C]ommonwealth is entitled to that inference based on the proof presented and wasn't given it." Id. at 16.

The trial court disagreed with this conclusion when it granted Wyatt's motion.

The evidence of record would, if believed by a jury, be sufficient to demonstrate [Wyatt's] carelessness , however, the Commonwealth has not presented any evidence to conclude [Wyatt] was engaging in any conduct that would raise his culpability to a conscious disregard of a substantial risk so as to reach the level of reckless or grossly negligent behavior.
The Commonwealth's entire case rests on its assumption that [Wyatt] was distracted while driving, although Trooper Waters clearly testified at the Omnibus Hearing that no evidence exists to prove the requisite standard that [Wyatt] was distracted. In essence, the Commonwealth argues that this fatal motor vehicle accident occurred when, for factually unexplained reasons, [Wyatt] failed to maintain his lane of travel; and that, because non-criminal causes (i.e. , weather, mechanical defects in the vehicles, or defects in the road) have been ruled out, [Wyatt] must have acted recklessly.

Trial Court Opinion and Order, 6/20/2018, at 11 (emphasis in original; citations omitted).

Our review of the record reveals that at the hearing on Wyatt's petition, the Commonwealth relied in part on the Collision and Accident Reconstruction Specialist (CARS) report, which concluded that speed, weather conditions, and mechanical defects were not contributing factors to the vehicle collision. N.T., 4/13/2018, at 25, 27-28. The report also explored a potential human element of distracted driving, noting that the cab of the truck contained food, beverages, radios, and two unrestrained dogs. The report ultimately concluded that driver distraction could not be ruled out as a contributing factor. Id. at 29.

The Commonwealth also presented a GPS report from a device that recorded certain periodic driving statistics from Wyatt's tractor-trailer. Id. at 29. Specifically, it indicated that Wyatt started the ignition on his...

To continue reading

Request your trial
8 cases
  • Commonwealth v. Bostian
    • United States
    • Pennsylvania Superior Court
    • May 14, 2020
    ...argues that Judge McDermott erred in relying upon Commonwealth v. Karner , 193 A.3d 986 (Pa. Super. 2018), and Commonwealth v. Wyatt , 203 A.3d 1115 (Pa. Super. 2019), to support the application of the clearly erroneous exception to the coordinate jurisdiction rule. See Commonwealth Brief a......
  • Commonwealth v. Fretts
    • United States
    • Pennsylvania Superior Court
    • October 4, 2021
    ...to establish a prima facie case with respect to the crime of homicide by vehicle and the other charges. Commonwealth v. Wyatt , 203 A.3d 1115, 1117 (Pa. Super. 2019) ; Commonwealth v. Dantzler , 135 A.3d 1109, 1112 (Pa. Super. 2016) (en banc ).4 To establish a prima facie case, the Commonwe......
  • Commonwealth v. Fortunato
    • United States
    • Pennsylvania Superior Court
    • May 27, 2022
    ...the Commonwealth is sufficient to establish a prima facie case with respect to the charges against the defendant. Commonwealth v. Wyatt , 203 A.3d 1115, 1117 (Pa. Super. 2019) ; Commonwealth v. Dantzler , 135 A.3d 1109, 1112 (Pa. Super. 2016) (en banc ). To establish a prima facie case, the......
  • Commonwealth v. Ros
    • United States
    • Pennsylvania Superior Court
    • July 7, 2022
    ...(Id. at 8, 26). Under these circumstances, the Commonwealth established a prima facie case for burglary and the related offenses. See Wyatt, supra. the conspiracy charge, Appellee and her co-defendants fled from a vehicle containing stolen merchandise and a firearm. Although the Commonwealt......
  • Request a trial to view additional results

VLEX uses login cookies to provide you with a better browsing experience. If you click on 'Accept' or continue browsing this site we consider that you accept our cookie policy. ACCEPT