State of Louisiana v. Matthew L. Magrini, 301 So.3d 525

March 12, 2016: a single-motorcycle crash at Broadway & Washington in New Orleans killed passenger George Paitich and seriously injured Matthew Magrini; the bike struck a telephone pole.
Eyewitness David Zibro (and a chaperone) saw the motorcycle pass at high speed and identified a heavier, bearded man (Magrini) as the driver; a Snapchat video timestamped 9:07 p.m. shows Magrini driving; a 911 call followed at 9:08 p.m.
Hospital testing showed Magrini’s BAC = .232; the victim’s BAC = .253; medical testimony classified the victim’s death as accidental and placed causation issues in the factual mix.
Magrini was charged under La. R.S. 14:32.1(A)(2) and (A)(4) (vehicular homicide based on BAC) and convicted by jury after a two-day trial; the trial record included eyewitness testimony, the Snapchat video, medical records, photographs, and a witness statement.
Post-trial: court adjudicated Magrini a third-felony habitual offender and resentenced him to 25 years’ hard labor; the appellate court affirmed the conviction but remanded for the trial court to impose the mandatory fine and to apply the sentencing conditions required by La. R.S. 14:32.1(B) and (C).
Magrini’s motions claiming prejudice from loss of original trial exhibits were denied after the State supplemented the record with authentic copies; Magrini’s contentions on sufficiency and certain evidentiary objections were considered on appeal.

Issue	State's Argument	Magrini's Argument	Held
Sufficiency of evidence to prove Magrini was the driver and that his BAC contributed to death	Direct eyewitness ID (Zibro), Snapchat video showing Magrini driving, hospital BAC .232, and circumstantial facts exclude reasonable hypotheses of innocence	Evidence insufficient: initial reports listed victim as driver, some EMS/police reports conflicted, and switching positions between video and crash was possible	Affirmed: viewing evidence most favorably to State, a rational jury could convict; eyewitness testimony + video + BAC supported both driver ID and causation
Motion to vacate / lost exhibits (right to complete record)	State located and filed authentic copies of trial exhibits; appellate review adequate	Loss of originals deprived Magrini of a complete record and appellate review	Denied: supplementation cured omission; no prejudice shown; appellate record sufficient
Admissibility of State Farm insurance records	Records were properly authenticated and admitted under business-records rules; defense had contemporaneous opportunity to object	Admission violated confrontation and hearsay rights; lack of insurer custodian at trial prejudiced Magrini	No reversible error found on appeal: trial objection preserved only on self-authentication ground; new bases raised on appeal not considered

Jackson v. Virginia, 443 U.S. 307 (1979) (sets constitutional standard for sufficiency review)
Hardy v. United States, 375 U.S. 277 (1964) (right to appellate review on a complete record)
State v. Deruise, 802 So.2d 1224 (La. 2001) (defendant entitled to complete trial transcript for appeal; material omissions require reversal)
State v. Castleberry, 758 So.2d 749 (La. 1999) (inconsequential omissions in the record that do not prejudice defendant do not mandate reversal)
State v. Morris, 414 So.2d 320 (La. 1982) (circumstantial-evidence standard: prosecution must exclude every reasonable hypothesis of innocence)
State v. Kalathakis, 563 So.2d 228 (La. 1990) (causation is a factual determination judged by totality of circumstances)
State v. Taylor, 463 So.2d 1274 (La. 1985) (vehicular homicide requires proof that unlawful BAC plus operation of vehicle caused death)
State v. Bruins, 407 So.2d 685 (La. 1981) (habitual-offender penalty references the sentencing provisions of the underlying offense)