Pennsylvania v. Howard (opinion announcing the judgment of the court)
Annotate this CaseIn 2017, Appellant Waylynn Howard (Mother) and her three-year-old daughter (Child) were riding in a car-for-hire which was involved in a three-vehicle accident on a state highway outside of Pittsburgh. At the time of the accident, Mother was sitting in the front passenger seat of the vehicle, and Child was sitting in the back seat, on the passenger side. There was no car seat in the vehicle, and none of the occupants were wearing seatbelts. None of the individuals involved sustained serious injuries. A police officer responded to the scene, and, based on his affidavit of probable cause, Mother was charged with reckless endangerment of another person, and endangering the welfare of a child, a first-degree misdemeanor. At a stipulated bench trial based entirely on the affidavit of probable cause, Mother was convicted of both offenses. The trial court imposed a sentence of one year probation for Mother’s conviction for endangering the welfare of a child, and no further penalty for her conviction for reckless endangerment. Mother appealed, challenging the sufficiency of the evidence to sustain both of her convictions. In an unpublished memorandum opinion, a divided panel of the Superior Court reversed Mother’s conviction for reckless endangerment of another person, finding her actions did not rise to the level of criminal recklessness. However, the panel affirmed Mother’s conviction for endangering the welfare of a child. In this appeal by allowance, the issue presented for the Pennsylvania Supreme Court’s review centered on whether whether evidence that a parent allowed her child to ride in a car-for-hire without being restrained by a child safety seat was, without more, sufficient to support a conviction for endangering the welfare of children under 18 Pa.C.S. 4304(a)(1). The Court concluded that it was not. Accordingly, the Superior Court’s decision was reversed and Appellant’s conviction and judgment of sentence were vacated.
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