## Facts

- Gary R. Huggins drove a 15-passenger van eastbound on Interstate 80 in clear weather and admitted he fell asleep at the wheel.
- The van rear-ended a Saturn sedan, then crossed lanes, struck an embankment, flipped, and came to rest partly in the travel lane.
- The van carried 24 occupants, including 21 minors (nearly all under age twelve); because seating was limited, some children were crowded into seats and others sat on the floor.
- An accident reconstruction expert estimated Huggins’s speed at at least 78 mph in a 55 mph zone.
- None of the passengers was restrained by seatbelts.
- Two children died and many others were injured.
- Huggins was charged with multiple offenses, including two counts of involuntary manslaughter under 18 Pa. C.S. § 2504(a).
- At the preliminary hearing, the issuing authority dismissed the involuntary manslaughter (and related homicide-by-vehicle) counts for lack of a prima facie showing of recklessness or gross negligence; the Court of Common Pleas and Superior Court affirmed.
- The Pennsylvania Supreme Court granted review to determine whether the Commonwealth’s preliminary-hearing evidence established a prima facie case of involuntary manslaughter.

## Issues

1. Whether the Commonwealth’s preliminary-hearing evidence was sufficient to establish a prima facie case that Huggins caused two deaths by performing a lawful or unlawful act in a reckless or grossly negligent manner under 18 Pa. C.S. § 2504(a).
2. Whether the issuing authority and reviewing courts improperly treated “falling asleep” in isolation and effectively weighed competing inferences and credibility at the preliminary-hearing stage.

## Decision

- The Pennsylvania Supreme Court reversed the dismissal of the two involuntary manslaughter counts.
- The Court held the Commonwealth presented sufficient evidence, if accepted as true, to permit a jury to find recklessness or gross negligence and causation under § 2504(a).
- The Court remanded for trial on the involuntary manslaughter charges.

## Legal Principles

- At a preliminary hearing, the Commonwealth need only present evidence that, if accepted as true, would warrant submission of the case to a jury; the standard is not proof beyond a reasonable doubt.
- The issuing authority may not make credibility determinations, weigh the evidence, or resolve competing inferences that are for the fact-finder at trial.
- Involuntary manslaughter under 18 Pa. C.S. § 2504(a) is shown by causing death as a direct result of an unlawful act performed recklessly or with gross negligence, or a lawful act performed recklessly or with gross negligence.
- Recklessness/gross negligence may be inferred from the totality of risk-creating conduct; multiple dangerous driving choices (e.g., excessive speed, overloading a vehicle, transporting unrestrained young children, and falling asleep) may be considered together rather than in isolation.
- Even if “falling asleep” alone may not always establish recklessness without specific proof of prior drowsiness, the surrounding circumstances can support an inference of a substantial and unjustifiable risk consciously disregarded.

## Conclusion

The court reinstated the involuntary manslaughter charges because the Commonwealth’s evidence of excessive speed, extreme overcrowding, unrestrained child passengers, and the ensuing crash supported a prima facie inference of reckless or grossly negligent conduct and causation, and the lower courts exceeded the limited preliminary-hearing role by effectively weighing the evidence.


Commonwealth v. Huggins, 836 A.2d 862 (Pa. 2003)