Queeman v. State

Rule of Law:

A driver's failure to control speed and maintain a proper distance, resulting in a fatal accident, does not constitute criminally negligent homicide without additional evidence of more egregious conduct, such as excessive speeding, intoxication, or other seriously blameworthy actions that show a gross deviation from the ordinary standard of care.

Facts:

• Robert Alan Queeman was driving his van eastbound on a two-lane highway.
• An SUV, driven by Maria del Rosario Luna and occupied by two passengers, was traveling in front of Queeman.
• The SUV slowed down or stopped on the highway to make a left turn.
• Queeman's van rear-ended the SUV, causing it to roll over into the oncoming lane of traffic where it was struck by a truck.
• Olga Deleon, a passenger in the SUV, died as a result of the injuries sustained in the collision.
• A state trooper's investigation concluded that the SUV's brake lights were illuminated at the time of the collision.
• Queeman was not suspected of being intoxicated or otherwise impaired at the time of the accident.
• The trooper cited Queeman for failure to control speed but not for speeding over the posted limit.

Procedural Posture:

• Robert Alan Queeman was indicted for manslaughter and criminally negligent homicide in a Texas trial court.
• A jury acquitted Queeman of manslaughter but convicted him of criminally negligent homicide.
• The trial court sentenced Queeman to eighteen months' confinement in a state jail facility.
• Queeman (as appellant) appealed his conviction to the Texas Court of Appeals (an intermediate appellate court), arguing the evidence was legally insufficient.
• The Court of Appeals reversed the trial court's judgment and rendered a judgment of acquittal.
• The State (as petitioner) sought and was granted discretionary review by the Texas Court of Criminal Appeals (the state's highest court for criminal cases).