In some states, like California, it can be 2nd degree murder from an auto accident. Usually, to be murder, it needs to be driving the wrong way on an interstate, racing on residential streets, or something like that, usually while over the legal alcohol limit.
In Cali, it boils down to “malice aforethought”, which can be either express or implied.
The jury instructions elucidate:
https://www.justia.com/criminal/docs/calcrim/500/520/