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.