Key point. Drivers of church vehicles may be criminally liable for involuntary manslaughter if they operate a vehicle in a grossly negligent or reckless manner that results in the death of one or more persons.
The Pennsylvania Supreme Court upheld the involuntary manslaughter conviction of the driver of a 15-passenger van who fell asleep at the wheel while transporting 21 children, causing an accident in which two children were killed and many more seriously injured.
At 5 p.m. on a sunny afternoon, an adult male (Steve) was driving a Ford 15-passenger van when, by his own admission, he fell asleep. He claimed he awoke just before the van collided with another vehicle, causing it to veer sharply to the right and hit an embankment. The van rode up the embankment, flipped, and came to rest on its passenger side. At the time of the collision there were 24 occupants in the van, including 21 minors. All but one of the minors was under the age of 12. Two of the children were killed in the crash, and numerous others were taken to hospitals with injuries. Because the van had only 15 passenger seats, some of the 23 passengers were crowded into seats while others were seated on the floor. An investigation by an accident reconstruction expert revealed that, at the time of the collision, none of the passengers was restrained by a seatbelt and the van was traveling at 78 miles per hour (23 miles over the posted speed limit of 55 miles per hour).