State Of Louisiana v. Kamron Kajon Jacquot
392 So.3d 663
La. Ct. App.2024Background
- Kamron Kajon Jacquot was indicted in Louisiana for first degree murder and attempted first degree murder stemming from a shooting incident at a New Year’s Eve party on December 31, 2020.
- The incident began with an altercation at the party between Jacquot and Eric Thibodaux, both of whom had romantic connections to a woman at the party, escalating to a fight in which Jacquot was outnumbered.
- As Thibodaux and Matthew Badeaux, another partygoer, walked away from the party after the altercation, Jacquot pursued them and opened fire from behind, killing Thibodaux and injuring Badeaux.
- Multiple eyewitnesses identified Jacquot as the shooter, and bodycam/video evidence and forensic testimony corroborated the sequence of events, including that most shots were fired from behind.
- A jury convicted Jacquot of second degree murder (of Thibodaux) and attempted manslaughter (of Badeaux). He appealed, challenging only the murder conviction, arguing self-defense or, alternatively, that the crime should be reduced to manslaughter due to “sudden passion”.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether evidence was sufficient for murder | State proved murder, not self-def. | Jacquot acted in self-defense or in sudden passion. | Evidence sufficient; self-defense rejected. |
| Whether killing was in self-defense | Jacquot was aggressor; no danger | He reasonably believed he was in imminent danger. | Jacquot not facing imminent danger; not justified. |
| Whether crime should be reduced to manslaughter | No sufficient provocation | Provoked; acted in heat of blood/sudden passion. | No adequate provocation; jury finding upheld. |
| Whether inconsistent verdicts required reduction | Compromise verdicts allowed | Inconsistent verdicts require reduction to manslaughter. | Compromise verdicts allowed; no reduction. |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (1979) (articulates the federal standard for reviewing sufficiency of criminal evidence).
- State v. Lawson, 885 So. 2d 618 (La. App. 5 Cir. 2004) (sentence to Department of Corrections is at hard labor by law).
- State v. Cousan, 684 So. 2d 382 (La. 1996) (specific intent can be formed instantly and inferred from shooting).
- State ex rel. Ellaire v. Blackburn, 424 So. 2d 246 (La. 1982) (judicial tolerance for inconsistent jury verdicts; compromise verdicts permitted).
- State v. Calloway, 1 So. 3d 417 (La. 2009) (appellate courts should not substitute their judgment for that of the jury on credibility/evidence).
