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Kayla Jean Lardieri v. State
03-15-00247-CR
Tex. App.
Jan 13, 2017
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Background

  • On a December night 2013, 17‑year‑old Kayla Lardieri and two other women attacked a victim in a trailer: the victim was stabbed, tased repeatedly, beaten, handcuffed, gagged, blindfolded, shackled, hogtied, wrapped in a sheet, and left in a locked shed naked on a freezing night.
  • The attackers gathered the victim’s possessions; Lardieri and her boyfriend accompanied items (and clothing) to a location where items were burned; some co‑defendants recorded the attack and one deleted the recording.
  • The victim escaped, was found the next morning bleeding and cuffed, identified her assailants, and received extended medical treatment for multiple stab wounds and other injuries.
  • Lardieri was indicted and convicted by a jury of attempted capital murder, aggravated robbery, aggravated kidnapping, and tampering with physical evidence; acquitted of aggravated sexual assault. Sentences: thirty years for the three felonies (concurrent) and ten years for tampering (concurrent).
  • On appeal Lardieri challenged the factual sufficiency of the evidence for attempted capital murder, aggravated robbery, and tampering; the court applied the Jackson v. Virginia legal‑sufficiency standard (per Brooks) and affirmed.

Issues

Issue Appellant's Argument State's Argument Held
Sufficiency of evidence for attempted capital murder (intent element) No evidence any defendant intended to kill; only intended to “scare” the victim Circumstantial evidence (violence, extent of wounds, leaving victim tied in cold shed, statements and conduct) supports an inference of intent to kill Evidence legally sufficient under Jackson to support attempted capital murder conviction as principal; issue overruled
Sufficiency of evidence for aggravated robbery (theft element/party liability) Lardieri did not intend to steal and did not personally take the victim’s property Co‑defendants gathered property, Lardieri participated in gathering and accompanying items to be disposed of; theft could be inferred and was foreseeable as part of the conspiracy/party liability Evidence legally sufficient to convict Lardieri as a party to aggravated robbery; issue overruled
Sufficiency of evidence for tampering with physical evidence (alter/destroy with knowledge an offense occurred) Boyfriend testified he alone burned items; no direct evidence Lardieri destroyed evidence Testimony and recorded statement indicate Lardieri participated in burning clothes and accompanied boyfriend to burn site; jury could infer she aided and intended to impair evidence Evidence legally sufficient to convict Lardieri as a party to tampering; issue overruled

Key Cases Cited

  • Jackson v. Virginia, 443 U.S. 307 (1979) (legal‑sufficiency standard: whether any rational trier of fact could find guilt beyond a reasonable doubt)
  • Brooks v. State, 323 S.W.3d 893 (Tex. Crim. App. 2010) (Jackson is the sole standard for sufficiency review in Texas criminal appeals)
  • Guevara v. State, 152 S.W.3d 45 (Tex. Crim. App. 2004) (motive and circumstantial evidence can indicate guilt)
  • Patrick v. State, 906 S.W.2d 481 (Tex. Crim. App. 1995) (intent may be inferred from extent of injuries)
  • Clayton v. State, 235 S.W.3d 772 (Tex. Crim. App. 2007) (jury as fact‑finder entitled to weigh credibility and resolve conflicts)
  • Anderson v. State, 416 S.W.3d 884 (Tex. Crim. App. 2013) (verdict upheld if sufficient on any theory authorized by the charge)
  • Ladd v. State, 3 S.W.3d 547 (Tex. Crim. App. 1999) (same principle for multi‑theory jury charges)
  • Hooper v. State, 214 S.W.3d 9 (Tex. Crim. App. 2007) (circumstantial evidence can be as probative as direct evidence)
Read the full case

Case Details

Case Name: Kayla Jean Lardieri v. State
Court Name: Court of Appeals of Texas
Date Published: Jan 13, 2017
Docket Number: 03-15-00247-CR
Court Abbreviation: Tex. App.