Commonwealth v. Satterfield: Single Violation for Leaving Scene

The case of Commonwealth v. Satterfield involved a legal challenge to the sentencing of Jack Edward Satterfield, who was convicted of multiple counts of leaving the scene of an accident involving death or personal injury under Pennsylvania law. The Supreme Court of Pennsylvania reviewed whether Satterfield could be sentenced separately for each victim in a multi-vehicle crash or whether his failure to remain at the scene constituted a single offense. The court ruled that Satterfield could only be punished once for leaving the scene, reversing the lower court’s decision and vacating two of his three sentences.

Background and Legal Issues

On October 12, 2018, Satterfield was driving a tractor-trailer through Dauphin County, Pennsylvania, when he approached a construction zone at high speed and crashed into multiple stopped vehicles. The collision resulted in three fatalities and several injuries. After the crash, Satterfield exited his truck and fled to a nearby parking lot, where he was later apprehended by police.

Satterfield pleaded guilty to multiple offenses, including:

• Three counts of leaving the scene of an accident involving death or personal injury under 75 Pa.C.S. § 3742.
• Three counts of homicide by vehicle while driving under the influence.
• Other related traffic and alcohol offenses.

At sentencing, the trial court imposed separate consecutive sentences for each of the three counts of leaving the scene, contributing to an aggregate sentence of 28.5 to 63 years in prison. Satterfield appealed, arguing that his actions constituted a single violation of the hit-and-run statute and that he should not have received multiple sentences.

Court’s Analysis and Findings

The Supreme Court of Pennsylvania analyzed whether the statutory language of 75 Pa.C.S. § 3742 allowed for multiple punishments based on the number of victims. The court found that:

• The statute criminalizes the act of leaving the accident scene before fulfilling legal obligations, not the number of victims involved.
• The unit of prosecution for a violation of § 3742 is a driver’s failure to remain at the scene and render aid, making it a "scene-based" offense rather than a "victim-based" offense.
• The law does not specify that penalties should be imposed per victim, unlike other Pennsylvania statutes that explicitly require sentencing "for each victim."
• The legislative history did not support interpreting the statute to allow multiple sentences for a single departure from the accident scene.

Given these findings, the court determined that Satterfield’s departure from the scene constituted only one offense under § 3742. Thus, two of his three sentences were illegal.

Conclusion and Ruling

The Supreme Court of Pennsylvania reversed the lower court’s decision and vacated two of Satterfield’s three sentences for leaving the scene of an accident. The case was remanded for resentencing, clarifying that under Pennsylvania law, a driver can only be punished once for leaving the scene of an accident, regardless of how many victims were involved.

Legal Guidance for Motor Vehicle Collision Cases

Navigating the legal implications of motor vehicle accidents can be complex. Our team at Whitcomb, Selinsky, PC assists clients in addressing legal challenges related to personal injury claims, motor vehicle collisions, and related legal matters.