Commonwealth v. Melvin Garcia-Rivera 2009 PA Super 213 (11/05/2009)

Topic: Sentencing – Deviation from the Sentencing Guidelines – Consecutive Sentences for Multiple Deaths Arising From a Single Event

Summary: 1.) When issuing a sentence in the mitigated range of the sentencing guidelines, the sentencing court is required to state its reasons for the downward deviation on the record.  2.) A person convicted of homicide by vehicle under 75 Pa.C.S.A. § 3732 may be sentenced separately for each death caused by the automobile accident.

http://www.aopc.org/OpPosting/Superior/out/S21040_09.pdf