State of Louisiana v. Tyrone Steele
2024-KA-0452
La. Ct. App.Jun 12, 2025Background
- Tyrone Steele was indicted on multiple counts related to the murders of four individuals, including Shane Brown, in New Orleans on March 21, 2022.
- Steele was found guilty by a jury of multiple counts, including the responsive verdict of second-degree murder for the death of Shane Brown, but acquitted of other charges including one for Donald McNeil’s murder.
- The prosecution's evidence included surveillance video footage, DNA analysis, Instagram social media postings linked to Steele, and ballistics.
- Central to the case was the authentication and evidentiary value of an Instagram account purportedly belonging to Steele, which posted incriminating content about the crimes.
- Steele appealed his second-degree murder conviction, challenging the sufficiency of the evidence, the authentication of the Instagram evidence, and the denial of his motion for mistrial.
- On appeal, the court affirmed Steele's conviction but remanded for clarification of sentencing on certain ancillary counts due to ambiguity regarding benefits eligibility.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Authentication of Instagram evidence | State submitted sufficient circumstantial evidence to link Steele to the Instagram account. | Steele argued lack of sufficient authentication; not proven his. | Sufficient evidence for authentication; admissible. |
| Sufficiency of the evidence for second-degree murder | State showed circumstantial evidence (DNA, video, gun, timing) proving Steele killed Brown. | State did not exclude every reasonable hypothesis of innocence. | Evidence sufficient, including for potential greater crime. |
| Denial of motion for mistrial (re Instagram) | No prejudice resulted from admission; posts properly linked to Steele by circumstantial proof. | Introduction of Instagram posts was unduly prejudicial. | No abuse of discretion; denial affirmed. |
| Patent sentencing error (counts 2-4) | N/A | N/A | Remanded for clarification of sentencing terms/benefits. |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (1979) (sets forth standard for reviewing sufficiency of the evidence in criminal cases)
- State v. Captville, 448 So.2d 676 (La. 1984) (addresses the standard when reviewing circumstantial evidence; rational trier can reject defendant's hypothesis)
- State v. Castleberry, 758 So.2d 749 (La. 1999) (mistrial is an extreme remedy for substantiated prejudice)