In Commonwealth v. Arrington, the defendant appealed his convictions of various offenses, including Involuntary Manslaughter, Conspiracy to Commit Involuntary Manslaughter, and Drug Delivery Resulting in Death. On appeal, he argued that Conspiracy to Commit Involuntary Manslaughter is not cognizable in PA; that venue was proper in a different county; and that the trial court should have dismissed a juror because the juror had a 4-minute conversation with a police officer, who was a witness. The Pennsylvania Superior Court affirmed. The Court concluded: 1. the Conspiracy to Commit Involuntary Manslaughter is a cognizable offense in Pennsylvania; 2. venue was proper in the county where the victim died as opposed to that where drugs were delivered; 3. the trial court did not abuse its discretion in declining to remove the juror.
