State Of Louisiana v. Dedrick L. Labee, 361 So.3d 1072

Indictment: Dedrick Labee charged with second-degree murder, armed robbery (acquitted), and obstruction of justice by tampering with evidence; convicted of murder and obstruction after jury trial; post-verdict acquittal motion denied.
Incident (July 29, 2020): victim Wayne Bourliea shot five times inside Z Equipment shop; body found behind the counter; no eyewitnesses besides defendant.
Defendant's account: argued with Wayne over a receipt, claimed Wayne threatened to kill him and bent down as if reaching for an ankle gun; Labee retrieved a gun and shot Wayne, then fled; returned briefly to retrieve items and later turned himself in the next day.
Physical evidence: a gun owned by the shop remained holstered in a bag and was not fired; victim had no weapon; autopsy showed four close-range shots to the back (including back of head) and one shot to the chest.
Conduct after shooting: defendant fled, discarded victim’s phone, later claimed to have dismantled and discarded the murder weapon; the murder weapon was never recovered.
Sentencing: life imprisonment at hard labor without parole for second-degree murder and 40 years at hard labor for obstruction, to run consecutively; convictions and sentences affirmed on appeal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence to disprove self-defense for second-degree murder	Evidence disproves self-defense; jury could infer intent from conduct and wound pattern	Labee acted in self-defense, reasonably believed he faced imminent deadly harm	Affirmed — viewed in light most favorable to State, jury could reject self-defense; evidence sufficient under Jackson standard
Denial of post-verdict judgment of acquittal	Denial proper because evidence supported convictions	Trial court should have granted acquittal	Affirmed — trial court did not err in denying the motion

Jackson v. Virginia, 443 U.S. 307 (U.S. 1979) (establishes sufficiency-of-evidence standard for criminal convictions)
Captville v. State, 448 So. 2d 676 (La. 1984) (jury rejection of defendant’s hypothesis of innocence is binding when rational)
State v. Mickelson, 149 So. 3d 178 (La. 2014) (specific intent may form instantly and be inferred from conduct)
State v. Reed, 200 So. 3d 291 (La. 2016) (pointing and firing a gun can support inference of intent to kill)
State v. Eby, 248 So. 3d 420 (La. App. 1st Cir. 2016) (appellate deference to jury credibility determinations)
State v. Calloway, 1 So. 3d 417 (La. 2009) (applies Jackson standard on review of sufficiency)