District Judge Joseph F. Bianco
Uribe crashed his SUV into a tree at 2:20 one morning. Blocking traffic, all of the SUV’s lights went out, making it invisible to oncoming vehicles. A taxi crashed into Uribe’s disabled SUV. Moments later motorcyclist Gaudesi crashed into Uribe’s SUV. Gaudesi died. Among other crimes, a jury convicted Uribe of second-degree vehicular manslaughter. Convictions were upheld, and New York’s high court denied leave to appeal. District Court denied Uribe 28 USC §2254 habeas relief challenging his indictment for vehicular manslaughter in the second degree. Sufficient evidence supported Uribe’s conviction. Uribe did not dispute trial evidence that he was impaired when he drove his SUV and that his collision with a tree started a chain of events leading to Gaudesi’s death. Under People v. DaCosta, an unbroken chain of events caused by a defendant that leads to a victim’s death established causation. It was irrelevant that Gaudesi may have been able to avoid the crash by using another lane or if he had not been potentially under the influence of drugs himself. Under Penal Law §125.12, once the elements of vehicular manslaughter could be established by a rational factfinder, what another driver could have done differently was irrelevant.