SPRINGFIELD, Mo., Sept. 1, 2026 , A Missouri appeals court has upheld an eight-year prison sentence for a commercial truck driver convicted of first-degree involuntary manslaughter after his tractor-trailer slammed into stopped traffic approaching an Interstate 44 construction zone, triggering a multi-vehicle crash that killed a woman.
The Missouri Court of Appeals Southern District issued its decision Monday, Aug. 31, affirming the conviction of Admir Kulovac in State of Missouri v. Admir Kulovac, case SD39130. Missouri’s official Case.net system confirms the appellate case and docket number.
The appellate court concluded that the evidence was sufficient for the trial judge to find Kulovac acted recklessly, not merely negligently, when the tractor-trailer continued toward stopped traffic despite miles of construction warnings and showed no apparent braking or evasive action before impact.
Truck Entered Construction Backup Without Apparent Braking
The crash happened in June 2023 on eastbound Interstate 44 in Jasper County.
According to the appellate opinion, traffic approaching a construction zone had completely stopped in the right lane while vehicles in the left lane had slowed nearly to a stop.
Kulovac’s tractor-trailer then struck the rear of a stopped vehicle, causing a multi-vehicle collision that killed its driver.
Contemporaneous reporting based on Missouri State Highway Patrol information identified the victim as 37-year-old Cortney Johnson of Sarcoxie and identified Kulovac as a 46-year-old Des Moines driver operating a 2011 Volvo tractor-trailer.
Johnson’s obituary independently confirms she died June 26, 2023, at age 37 as a result of a multi-car collision.
Six Miles of Construction Warnings
At Kulovac’s bench trial, Missouri State Highway Patrol Trooper Braiden Vaught testified that multiple lighted and orange construction-warning signs were positioned along roughly six miles of roadway approaching the work zone.
An eyewitness estimated the tractor-trailer was traveling faster than 50 mph before impact and testified that she saw neither brake lights nor a reduction in the truck’s speed.
A Missouri State Highway Patrol crash reconstructionist reached an even higher estimate.
Trooper Michael Eden testified that his reconstruction indicated the truck was traveling more than 60 mph and that investigators found no skid marks or other physical evidence suggesting an attempt to stop before the collision.
The appellate court also noted that the evidence revealed no mechanical problem with the tractor-trailer that contributed to the crash.
Driver Challenged Whether State Proved He Was Behind the Wheel
Kulovac appealed on two primary grounds.
First, he argued prosecutors had not sufficiently established that he was actually driving the tractor-trailer because no witness made a conventional in-court identification of him as the driver.
The appeals court rejected that argument.
Trooper Travon Smith testified that when he arrived at the scene, Kulovac was inside the tractor-trailer, wearing a seat belt and suffering from a facial injury.
The crash reconstruction report also described the truck’s driver as a 46-year-old man possessing a valid Iowa Class A commercial driver’s license and stated that there were no passengers inside the truck.
The court ruled that the circumstantial evidence was sufficient for the trial judge to determine beyond a reasonable doubt that Kulovac had been driving.
The court also noted that Kulovac’s defense attorney had conceded during opening statements that the collision was Kulovac’s fault. Missouri precedent allows certain factual concessions by counsel to operate as judicial admissions even though opening statements themselves are not evidence.
Recklessness Was the Bigger Legal Question
Kulovac’s second argument is the portion of the opinion with potentially broader implications for professional drivers and motor carriers.
Missouri law distinguishes between criminal negligence and recklessness.
First-degree involuntary manslaughter requires proof that a defendant recklessly caused another person’s death, meaning the person consciously disregarded a substantial and unjustifiable risk.
Kulovac argued prosecutors had not shown that level of mental culpability.
The appeals court disagreed.
The court acknowledged an important limitation: speed by itself does not necessarily establish criminal recklessness.
But the court cited Missouri precedent holding that “speed combined with other circumstances can satisfy this element of an offense.”
Here, judges pointed to the combination of circumstances: repeated construction warnings, surrounding traffic that had already slowed or stopped, the tractor-trailer’s speed, the absence of visible braking and the absence of skid marks suggesting an attempt to stop.
Court: Evidence Supported Finding Driver Consciously Disregarded Risk
The trial judge had emphasized that there was no evidence Kulovac attempted to slow, stop or swerve before impact.
The appeals court said those circumstances allowed the trial court to distinguish recklessness from a driver simply failing to notice a danger.
The Southern District concluded that the cumulative evidence allowed a reasonable fact-finder to determine Kulovac consciously disregarded the danger created by the traffic conditions approaching the construction zone.
That distinction matters.
A momentary mistake, missed sign or ordinary failure to perceive a hazard may constitute negligence under some circumstances. The Missouri court found the evidence in this case supported the substantially higher finding of criminal recklessness.
The three-judge panel unanimously affirmed the judgment. Chief Judge Becky J. West authored the opinion, with Judges Jack A. L. Goodman and Jennifer R. Growcock concurring.
Eight-Year Sentence Remains in Place
Kulovac had waived a jury trial and was convicted by the Jasper County Circuit Court of first-degree involuntary manslaughter.
The trial court sentenced him to eight years in prison.
Monday’s appellate decision leaves that conviction and sentence intact unless Kulovac successfully pursues additional appellate remedies.
For trucking, the decision is a reminder that a fatal rear-end collision can move beyond civil negligence and into criminal liability when prosecutors can prove a driver consciously disregarded an obvious and substantial danger.
The ruling does not create a rule that every failure to stop for construction-zone traffic constitutes manslaughter. The decision is tied to the specific evidence presented against Kulovac, including the extended warning zone, speed evidence, surrounding traffic conditions and lack of evidence that the truck attempted to slow or avoid the collision.
But the court’s reasoning is clear: when speed is combined with multiple warnings, visibly stopped traffic and no apparent evasive action, Missouri law can support a finding of criminal recklessness rather than a simple driving mistake.
