## Facts

- Leroy W. Root and the decedent agreed to race their automobiles on a rural three-lane public highway at night under clear, dry conditions with light traffic.
- The speed limit was 50 m.p.h.; the cars traveled at varying speeds of approximately 70–90 m.p.h.
- The accident occurred in a no-passing zone approaching a bridge where the roadway narrowed to two lanes of opposing traffic.
- Root was in the lead and driving in his right-hand lane.
- The decedent attempted to pass Root while a truck approached from the opposite direction; the decedent swerved left, crossed the center line, and struck the truck head-on, killing himself.
- Root’s conduct could support traffic-related offenses (e.g., speeding and reckless driving), but he was prosecuted and convicted of involuntary manslaughter for the decedent’s death.

## Issues

1. Whether Root’s unlawful and reckless participation in the race was a sufficiently direct cause of the decedent’s death to sustain an involuntary manslaughter conviction.
2. Whether tort-style “proximate cause” is an appropriate causation standard for criminal homicide when the victim’s voluntary act immediately produces the fatal result.
3. Whether the decedent’s decision to cross into oncoming traffic constituted a superseding cause that broke the causal chain.

## Decision

- The Supreme Court of Pennsylvania reversed the judgment of sentence.
- The court granted Root’s motion in arrest of judgment.
- The court held that, although Root’s conduct was unlawful and reckless, it was not the direct cause of the decedent’s death.
- The court treated the decedent’s voluntary act of swerving into oncoming traffic as the immediate and responsible cause of the fatal collision, severing criminal causation.

## Legal Principles

- Involuntary manslaughter requires (1) unlawful or reckless conduct and (2) a causal link in which the defendant’s conduct is the direct cause of death.
- Civil tort “proximate cause” concepts are broader than criminal causation and, standing alone, are insufficient to establish criminal homicide liability.
- A victim’s voluntary, independent, and reckless act that immediately produces death may function as a superseding cause, breaking the chain of causation for criminal homicide.
- Liability is more likely where the defendant’s conduct directly forces or immediately produces the fatal event; mere participation in a dangerous situation is not enough absent a direct causal connection.

## Conclusion

The court set aside Root’s involuntary manslaughter conviction because the decedent’s independent choice to cross into oncoming traffic, not Root’s racing in his own lane, directly caused the fatal collision, and criminal homicide requires a direct causal relationship beyond tort-style foreseeability.


Commonwealth v. Root, 170 A.2d 310 (Pa. 1961)