Daniel v. State

David Daniel (defendant) aggressively raced David Cabrera on an urban, highly trafficked highway in Arlington, Texas. Jose Reyes-Ramirez was driving with Ruben Escalante as his passenger when Reyes-Ramirez turned left on an unprotected green light, meaning that the oncoming traffic also had a green light. After Reyes-Ramirez completed the turn, but while his car was still in the intersection, Cabrera’s oncoming car slammed into the passenger side of Reyes-Ramirez’s car at 80 miles per hour. Daniel, who raced into the intersection side-by-side with Cabrera, dodged around the accident and continued driving. Escalante’s pelvis was badly broken, and Reyes-Ramirez was killed. The State of Texas charged Daniel with two counts of racing on a highway resulting in serious injury or death, a second-degree felony. At trial, Daniel denied that he was racing and denied seeing the accident occur. The jury found Daniel guilty, and he was sentenced to 12 years in prison. Cabrera was separately convicted on manslaughter charges. Daniel appealed. On appeal, Daniel admitted to racing but argued that (1) his racing was neither the but-for cause nor the proximate cause of the deadly crash, (2) Cabrera’s conviction for manslaughter precluded Daniel’s liability for Reyes-Ramirez’s death, and (3) Reyes-Ramirez turning left in front of Cabrera was the direct cause of the crash.