Commonwealth v. David K. Njuguna

Summary

The court held that the defendant's convictions for motor vehicle homicide and operating to endanger were duplicative of his involuntary manslaughter conviction because the Legislature clearly intended a tiered structure for these motor vehicle offenses. It upheld the involuntary manslaughter conviction because the evidence supported a finding that the defendant intentionally drove in a wanton or reckless manner, and it affirmed the denial of a new trial because the alleged failure to investigate impeachment evidence did not deprive him of a substantial defense. The court also reaffirmed the limited continuing force of the prior motor-vehicle duplicative-conviction rule while rejecting any broader conduct-based exception.