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Pennsylvania Supreme Court Announces Driver Who Leaves Scene of Accident Subject to Only One Hit-and-Run Violation, Regardless of How Many Victims

by Douglas Ankney

In a case of first impression, the Supreme Court of Pennsylvania held that a driver who leaves the scene of an accident involving death or personal injury before being statutorily excused may be punished for only one violation of 75 Pa.C.S. § 3742 (requiring driver of any vehicle involved in an accident to remain at the scene until duty to render aid and provide information satisfied) regardless of the number of persons killed or injured in the accident.

James Edward Satterfield crashed his tractor-trailer into numerous vehicles stopped at a construction zone, killing three people and causing a numerous injuries. Satterfield fled to the parking lot of a nearby hotel where a crowd had gathered to view the accident scene. Using a photograph, police were able to find Satterfield within the crowd and arrested him.

Satterfield pleaded guilty to multiple offenses, including three counts of violating § 3742, one count for each of the fatalities. The trial court sentenced him to three consecutive terms of three to six years in prison for the three violations of § 3742. Satterfield filed a post-sentence motion to modify his sentence, arguing that § 3742 “encompasses the act of not remaining at the scene of an accident where there has been injury or death to offer aid and information, [and he] could only leave the scene of an accident one time, not three, regardless of the number of victims.”

The trial court denied the motion, and Satterfield appealed. The Superior Court affirmed, and the Supreme Court allowed Satterfield an appeal to answer the question of what the “unit of prosecution” (the actus reus) is for a violation of § 3742(a), i.e., the single act of leaving the scene of an accident or each person injured or killed in the hit-and-run accident.

The Court stated that it must “determine what our General Assembly fixed as the unit of prosecution for a violation of Section 3742 (a). The unit of prosecution is the actus reus that the General Assembly intended to punish. Put otherwise, the unit of prosecution is the minimum conduct that must be proven to obtain a conviction for the statute in question.” To determine the correct unit of prosecution, the inquiry focuses on whether separate and distinct prohibited acts have been committed. Commonwealth v. Davidson, 938 A.2d 198 (Pa. 2007). This requires statutory interpretation. Commonwealth v. Wisneski, 29 A.3d 1150 (Pa. 2011). Words of a statute “shall be construed according to rules of grammar and according to their common and approved usage.” Pa.C.S. § 1903(a). When the words of a statute are clear and unambiguous, there is no need to look beyond the plain meaning of the statute under the pretext of pursuing its spirit. Commonwealth v. Brown, 981 A.2d 893 (Pa. 2009).

Turning to the statute at issue, § 3742 reads:

“(a) General rule.--The driver of any vehicle involved in an accident resulting in injury or death of any person shall immediately stop the vehicle at the scene of the accident ... [and] shall remain at the scene of the accident until he has fulfilled the requirement of section 3744 (relating to duty to give information and render aid)....”

Upon examining the statute, the Court determined that the plain meaning of “accident” and “scene” used in § 3742(a) means the unit of prosecution is “the act of leaving the scene of an accident without first rendering aid and providing the information required by Section 3744.” In Wisneski, the Supreme Court defined “accident” as “any untoward and unintended contact between a vehicle and something else.” And the term “scene” is defined as “the place of an occurrence or action.” Merriam-Webster Dictionary (online at www.merriamwebster.com).  The Court explained that “Section 3742(a) plainly instructs that a driver involved in an accident must ‘in every event … remain at the scene of the accident until he has fulfilled the requirements of 3744….’” Thus, the Court announced that “the unit of prosecution for the crime of hit-and-run in Section 3742 is the act of leaving the scene of an accident without first rendering aid and providing” the required information.

In the instant case, Satterfield’s leaving the accident scene without first fulfilling his obligations under § 3744 constituted but one violation of § 3742(a) and “may only be punished for one violation of Section 3742,” the Court concluded. Thus, the Court ruled that two of his hit-and-run sentences were illegal.

Accordingly, the Court reversed the order of the Superior Court, vacated his sentence of judgment, and remanded to the trial court for resentencing. See: Commonwealth v. Satterfield, 255 A.3d 438 (Pa. 2021). 

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Related legal case

Commonwealth v. Satterfield

 

 

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