PA Superior Court: Spouse’s Flight Into Traffic Was a Foreseeable Result of Defendant’s Assault, Not a Superseding Cause

Criminal Defense Lawyer Zak T. Goldstein, Esquire

The Pennsylvania Superior Court has decided the case of Commonwealth v. Garcia Arce, No. 405 MDA 2025 (Pa. Super. 2026), holding that a defendant's convictions for involuntary manslaughter and recklessly endangering another person ("REAP") were supported by sufficient evidence where his reckless driving, assault on the victim, and forcible removal of the victim from a vehicle in the median of a busy interstate foreseeably led to the victim’s death. The Court rejected the defendant’s argument that the victim’s decision to run into oncoming traffic constituted a superseding cause that broke the chain of causation. This is an important case for anyone facing involuntary manslaughter charges in Pennsylvania because it illustrates how broadly courts will apply the concept of legal causation even where the defendant did not directly inflict the fatal injury.

The Facts of Commonwealth v. Garcia Arce

The defendant and the victim, his spouse, were traveling westbound on Interstate 80 in Columbia County along with the victim’s elderly mother, who was seated in the back. The defendant. A verbal argument erupted after the defendant told the victim he wanted a divorce.

According to the victim’s mother, the defendant began speeding and swerving across the lane while screaming at the victim, who was trying to sleep. The defendant poked the victim and yelled at him to talk, growing increasingly angry when the victim did not respond. At one point, the victim reached over and turned off the car as the defendant drove into the grassy median of the highway.

Once the SUV stopped in the median just a few feet from the eastbound travel lanes, the situation escalated further. The mother testified that the defendant placed the victim in a chokehold, struck him with his cellphone, and then dragged him out of the vehicle through the driver’s side door. The victim was left standing in front of the SUV, bleeding from his face, just feet from high-speed traffic on a dark stretch of highway.

Moments later, the victim moved into the eastbound lanes and was struck and killed by a truck hauling a trailer. A second vehicle also hit the victim. The coroner testified that but for the events leading to the victim’s removal from the SUV and the assault he suffered, the victim would likely have survived. The coroner also ruled out the victim’s history of bipolar disorder as a contributing factor in his death, and noted that the head and facial injuries from the assault could have impaired his orientation and judgment.

The defendant testified in his own defense and offered a substantially different version of events. He claimed that the victim had grabbed the steering wheel, causing the vehicle to veer into the median, and that the victim then exited the SUV on his own and ran into traffic. However, investigators noted that the defendant gave inconsistent accounts of what happened, including conflicting descriptions of how the victim left the vehicle.

The jury convicted the defendant of involuntary manslaughter and REAP. The trial court had earlier granted a demurrer on an aggravated assault charge. The defendant was sentenced to ten months to two years of incarceration. He appealed.

The Superior Court's Analysis

On appeal, the defendant raised two main arguments: that the evidence was insufficient to sustain his convictions and that the verdict was against the weight of the evidence.

Sufficiency - Causation and Superseding Cause

The defendant’s primary argument was that the victim’s decision to run into traffic was an unforeseeable, independent act that broke the chain of causation. He argued that after the physical altercation ended, the victim voluntarily entered the roadway, and therefore the defendant’s conduct was not the direct cause of the victim’s death.

The Superior Court disagreed. Relying on Commonwealth v. Rementer, 598 A.2d 1300 (Pa. Super. 1991), the Court held that when a defendant’s violent assault causes the victim to flee, the victim’s flight, even into a dangerous situation, is a foreseeable consequence of the defendant’s actions, not a superseding cause. In Rementer, a defendant who violently assaulted a victim was convicted of third-degree murder after the victim fled into the path of a car. The Court held that although the precise mechanism of death was not foreseeable, the risk of serious injury or death was inherent in the situation the defendant created.

The Court applied the same reasoning here. The defendant’s reckless driving, his assault on the victim in the car, and his forcible removal of the victim from the SUV in the median of a busy interstate, in the dark, just feet from high-speed traffic, set in motion the chain of events that led to the victim’s death. The victim’s attempt to flee was a natural and predictable response to the defendant’s conduct. The Court emphasized that a defendant cannot create a dangerous situation through his own reckless behavior and then avoid criminal liability by arguing that the victim's response to that danger was unforeseeable.

Weight of the Evidence

The defendant also argued that the verdict was against the weight of the evidence, primarily attacking the credibility of the victim’s mother. He pointed to her poor eyesight, the darkness at the scene, her financial interest in wrongful-death litigation, and prior theft convictions. He also argued that other witnesses’ testimony actually supported his version of events.

The Superior Court found no abuse of discretion. The trial court had carefully considered these arguments and concluded that the jury was entitled to assess the credibility of the witnesses and choose whom to believe. The Court noted that DNA evidence, including the victim’s blood on the driver’s seat and door panel of the SUV, corroborated the mother’s account of the assault. The jury also viewed dash-camera footage of the fatal collision. The trial court’s determination that the verdict did not shock its sense of justice was well within its discretion.

The Takeaway

This is a significant case on the issue of legal causation in Pennsylvania homicide law. It reinforces the principle that when a defendant’s reckless conduct puts a victim in a dangerous situation, the defendant can be held criminally responsible for the victim's death even if the fatal injury was inflicted by a third party or resulted from the victim’s own attempt to escape. As long as the defendant’s conduct started the chain of events that led to the death, and the victim’s response was a foreseeable reaction to the danger the defendant created, the causal connection is established.

For defendants, this case is a reminder that causation in Pennsylvania criminal law extends beyond the immediate, direct infliction of harm. Prosecutors do not need to prove that a defendant personally delivered the fatal blow, only that the defendant’s reckless actions were a direct and substantial factor leading to the victim's death. The problem for the defendant here is that the death was almost immediate. had the defendant driven away and the victim been struck a few miles down the road while walking towards a rest stop, the result may have been different.

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