299 Pa. Super. 241 - Commonwealth v. Baker’s Empirical Analysis
1982
Citation profile
24 state decisions
How this case has been cited
Cited by 24 later decisions — most recently May 2016
24 state decisions
Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.
Relationships
Relies on Commonwealth v. Kichline · Commonwealth v. Goodwin · Commonwealth v. Brown · Commonwealth v. Houtz · Commonwealth v. Field
Most-quoted passages
The sentences later courts lift from this opinion, ranked by how many decisions quote each — the parts of the opinion doing the work. These counts are smaller than the citation total above because most of the 24 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Our Supreme Court has held that the legislature, in enacting this section, intended to “expand the scope of criminal liability for violations of the Vehicle Code causing death.” Commonwealth v. Field, 490 Pa. 519 , 525 n. 4, 417 A.2d 160 , 163 n. 4 (1980). “This legislative ‘expansion’ was accomplished not by the elimination of any of the elements of the crime of involuntary manslaughter, but by a relaxation of the degree of proof of two existing elements: culpable conduct and causation,” Commonwealth v. Houtz, 496 Pa. 345, 348 , 437 A.2d 385, 387 (1981). As in involuntary manslaughter, the Commonwealth must establish that the victim died, and that his death was a result of injuries sustained in the incident or of a chain of events stemming from the incident in order to prove homicide by vehicle. Unlike involuntary manslaughter, however, the Commonwealth need then only show that “the actor ‘knew or should have known,’ that he engaged in the conduct claimed to be in violation of the Vehicle Code and that at the very least, death was a ‘probable consequence’ of the conduct.” Id. Thus, although the homicide by vehicle statute lessens the Commonwealth’s burden of proving that the defendant’s illegal conduct was the legal cause of the victim’s death, the Commonwealth must still prove beyond a reasonable doubt that death occurred as a result of injuries received in the incident or of a chain of events stemming from the incident. If the Commonwealth fails to prove any one of the ele”
1 later decision quote this exact passage“may be sufficient to establish cause of death by a preponderance of the evidence, it does not satisfy the more stringent standard of criminal trials.”
1 later decision quote this exact passage
How this case has been treated — in progress
Whether each later court followed, distinguished, criticized, or overruled this decision. The treatment classification (task #35) runs highest-cited cases first and lights up here as it reaches this one.