## Facts

- Gilbert Vasquez went to the home of his friend Abel Rivera.
- While at the house, Vasquez argued with Abel’s brothers, Timotheo Rivera (defendant) and Gilbert Rivera.
- The argument turned violent and Vasquez was attacked by the brothers.
- Timotheo stabbed Vasquez six times.
- Gilbert shot Vasquez three times.
- Vasquez died from his wounds.
- Timotheo and Gilbert were charged separately.
- At Timotheo’s murder trial, the court instructed the jury it could convict if Timotheo either (a) caused Vasquez’s death himself, or (b) acted as a party with Gilbert in causing Vasquez’s death.
- The jury convicted Timotheo of murder and he received a life sentence.
- On appeal, Timotheo challenged the legal sufficiency of the evidence, arguing that the State failed to prove beyond a reasonable doubt that his conduct caused Vasquez’s death, including an argument that different medical treatment might have saved Vasquez.

## Issues

1. Was the evidence legally sufficient to prove that Rivera caused Vasquez’s death under Texas Penal Code causation standards, despite the claim that improved or different medical treatment could have prevented death?
2. Was the evidence legally sufficient under the jury charge authorizing conviction either as the principal actor or as a party to the murder?

## Decision

- The court of appeals affirmed the murder conviction and life sentence.
- The evidence was legally sufficient for a rational jury to find that Rivera’s stabbing was a “but for” cause of death, operating alone or concurrently with other causes.
- The possibility that medical treatment might have been more successful did not break the causal connection between Rivera’s conduct and the death.
- The evidence also supported conviction under the jury charge’s alternative theories, including liability as a party based on the brothers’ joint participation in the deadly assault.

## Legal Principles

- Legal sufficiency is measured under the Jackson v. Virginia standard: viewing the evidence in the light most favorable to the verdict, the question is whether any rational trier of fact could have found the essential elements beyond a reasonable doubt.
- Texas Penal Code § 6.04(a) provides causation for result-oriented offenses: a defendant is responsible if the result would not have occurred “but for” his conduct, operating alone or concurrently with another cause, unless the concurrent cause was clearly sufficient to produce the result and the defendant’s conduct was clearly insufficient.
- In homicide cases, negligent or imperfect medical care generally does not relieve a defendant of responsibility when the defendant inflicts dangerous or life-threatening injuries; the mere possibility that better treatment could have prevented death does not, by itself, sever causation.
- Under Texas party-liability rules (Texas Penal Code § 7.02), a defendant may be convicted for an offense committed by another if, acting with intent to assist, he solicits, encourages, directs, aids, or attempts to aid the other person in committing the offense.
- When a jury charge authorizes conviction on alternative theories (principal or party), the evidence is reviewed in light of the charge given, and the verdict may stand if the evidence supports at least one authorized theory.

## Conclusion

The court affirmed Rivera’s murder conviction because the evidence allowed a rational jury to find that Rivera’s stabbing was a “but for” cause of Vasquez’s death under Texas Penal Code § 6.04(a), and the suggestion that different medical care might have saved Vasquez did not sever causation; in addition, the coordinated attack with Rivera’s brother supported guilt under the jury charge’s principal-actor and party-liability alternatives.


Rivera v. State, 12 S.W.3d 572 (2000)