State of Louisiana v. Chadwick McGhee, 223 So. 3d 1136

Background

On Sept. 9, 2013 Jessica Guillot was forcibly taken after being dragged from one car into another; Asa Bentley strangled and threatened her; she later disappeared.
Bentley, Donnie Edwards, and Willie Price were active participants in the abduction; Chadwick McGhee was present throughout and closely associated with Bentley.
Evidence at trial: McGhee accompanied Bentley while searching for the victim, told the victim’s fiancé (Cecil Cooper) that the victim was in trouble, rode in the vehicle that brought the victim to Bentley, and was told by Bentley to obey him later that night.
McGhee denied knowledge of the theft accusation and denied being in the car with Price, Edwards, and the victim; his interview was played to the jury.
Trial court convicted McGhee as a principal to simple kidnapping; the court of appeal reversed for insufficient evidence that McGhee intended to aid the kidnapping.
The Louisiana Supreme Court reversed the court of appeal, holding the evidence—viewed in the light most favorable to the prosecution—was sufficient for a rational jury to find McGhee a principal (aid/abet).

Issues

Issue	State's Argument	McGhee's Argument	Held
Was evidence sufficient under Jackson v. Virginia to sustain conviction as a principal to simple kidnapping?	McGhee’s presence, participation in hunting the victim, role in transporting her, and close association with Bentley show he aided/abetted the kidnapping.	McGhee was only present, failed to act, and there is no proof he knew of or intended the kidnapping; mere presence is insufficient.	Reversed court of appeal: viewing evidence favorably to prosecution, jury could rationally find McGhee guilty as a principal.
Does mere presence at the scene establish principal liability?	Presence combined with acts (stalking, transport, statements of allegiance) supports inference of readiness to assist.	Mere presence and silence are not crimes; must show specific intent to aid.	Court reaffirmed that presence alone is insufficient, but here additional conduct supplied the requisite mens rea for a rational jury.
Appropriate standard of review for sufficiency challenges?	Apply Jackson v. Virginia — evidence viewed in light most favorable to prosecution; do not reassess credibility.	Same standard; argued that even under Jackson evidence was insufficient.	Jackson standard governs; under it appellate court must adopt the rational trier of fact’s view—resulting in reversal of the insufficiency ruling.
Whether appellate court improperly substituted its view for jury’s?	Appellate court erred by not adopting the prosecution-favorable view of contested facts and credibility.	Appellate court properly found reasonable doubt regarding intent.	Supreme Court held the court of appeal improperly substituted its view and must defer to jury’s reasonable inferences.

Key Cases Cited

Jackson v. Virginia, 443 U.S. 307 (establishes standard for sufficiency review: evidence must permit a rational trier of fact to find guilt beyond a reasonable doubt)
State v. Captville, 448 So.2d 676 (La. 1984) (adopts and explains Jackson standard in Louisiana)
State v. Mussall, 523 So.2d 1305 (La. 1988) (discusses deference to factfinder where reasonable interpretations differ)
State v. Holmes, 388 So.2d 722 (La. 1980) (requires proof the accused possessed the specific intent to aid or abet)
State v. Lubrano, 563 So.2d 847 (La. 1990) (jury may not speculate where reasonable jurors must have reasonable doubt)