State of Louisiana v. Raymond George Johnson, 277 So.3d 1263

Victim Yolanda Moore was found dead in Raymond Johnson’s home on April 29, 2017; autopsy showed 21 stab wounds (3 fatal) and toxicology showed BAC .203 and other substances.
Emergency responders found extensive blood throughout the house and on Johnson’s car; a bloody kitchen knife was recovered from Johnson’s yard; DNA from both Moore and Johnson was on the knife and at multiple locations.
Johnson had fresh, superficial lacerations; he gave varying statements to neighbors, first responders, and detectives, sometimes denying responsibility and sometimes saying Moore stabbed him or fell on glass.
Detectives interrogated Johnson at the police station after hospital treatment; Johnson was Mirandized, handcuffed, and made recorded statements including the almost-inaudible comment “I guess I better get a lawyer.”
The State introduced testimony of prior violent acts by Johnson against Moore and other women under La. C.E. art. 404(B); Johnson was convicted of second-degree murder and sentenced to mandatory life without parole.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence for 2nd-degree murder	State: evidence (stab wounds, DNA, scene, statements) supports specific intent to kill or inflict great bodily harm	Johnson: acted in self‑defense or at most manslaughter due to provocation and intoxication	Held: Evidence sufficient; jury could find intent and reject self‑defense; manslaughter not supported
Admission of other‑crimes (404(B)) evidence	State: prior domestic violence incidents show motive, intent, pattern and rebut self‑defense	Johnson: prior acts were remote, involved different victims, and were unfairly prejudicial	Held: Trial court did not abuse discretion; testimony admissible and, if error, harmless given overwhelming evidence
Invocation of right to counsel / suppression	Johnson: his remark (“I guess I better get a lawyer”) was an unequivocal invocation requiring cessation of questioning and suppression	State: remark was ambiguous/mumbled; officers reasonably did not understand it as invocation	Held: Trial court did not err; remark was not a clear, unambiguous request for counsel and statements were admissible
Request to reduce murder to manslaughter	Johnson: provocation and heat of passion should reduce offense	State: no evidence of sudden passion; defendant denied responsibility	Held: No evidence defendant met burden to prove manslaughter elements; conviction for 2nd‑degree murder affirmed

Jackson v. Virginia, 443 U.S. 307 (constitutional sufficiency of the evidence review)
Miranda v. Arizona, 384 U.S. 436 (Miranda warning and custodial interrogation requirements)
Davis v. United States, 512 U.S. 452 (requirement that request for counsel be unambiguous)
Edwards v. Arizona, 451 U.S. 477 (limitations on further interrogation after invocation of right to counsel)
Michigan v. Mosley, 423 U.S. 96 (police may resume questioning after certain invocations under circumstances)
Soffar v. Cockrell, 300 F.3d 588 (5th Cir.) (ambiguous references to counsel are insufficient to invoke right)
State v. Taylor, 217 So. 3d 283 (La. 2016) (standards for admissibility and balancing of other‑crimes evidence)
State v. Altenberger, 139 So. 3d 510 (La. 2014) (prior domestic abuse evidence probative of motive/pattern)
State v. Wilkins, 131 So. 3d 839 (La. 2014) (interpretation of La. R.S. 14:20 and ‘‘stand your ground’’ principles)
Sullivan v. Louisiana, 508 U.S. 275 (harmless‑error standard for constitutional errors)