Wyatt v. Commonwealth

LARRY G. ELDER, Judge.

Steven Michael Wyatt (appellant) appeals from his jury trial conviction for aggravated involuntary manslaughter under Code § 18.2-36.1(B). 1 On appeal, he contends the evidence was insufficient to support a finding that his conduct causing a death “was so gross, wanton and culpable as to show a reckless disregard for human life,” as required for a conviction for violating Code § 18.2-36.1(B). We hold the evidence was sufficient to support a finding that appellant was criminally negligent, and we affirm the conviction.

I

BACKGROUND

Shortly after 7:15 p.m. on November 28,…