State of Louisiana vs. Curtis Lee Stewart, Jr., 2025-K-01032

Curtis Lee Stewart, Jr. was indicted for second degree murder after Devonta Ennis was shot and killed on Prescott Road in Baton Rouge on April 25, 2021. 1
The shooting was captured on surveillance video, and a white Chevrolet Traverse and silver Nissan Armada were linked to the crime and later found burned nearby. 2
At bench trial, the court found Stewart guilty and imposed life imprisonment without benefits. 3
The First Circuit reversed, citing no physical evidence, no witness identification, and insufficient proof Stewart was the shooter. 4
This court granted certiorari to decide whether the evidence was sufficient under Jackson v. Virginia. 5
The Supreme Court reversed the court of appeal and reinstated the conviction and sentence. 6

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was the evidence sufficient under Jackson? 7	State: circumstantial evidence proved guilt beyond a reasonable doubt.	Stewart: evidence was speculative and did not identify him as the shooter.	Yes; a rational factfinder could convict beyond a reasonable doubt. 8
Did the State need to prove Stewart was the actual shooter? 9	State: principal liability supported conviction even without proof he fired the fatal shots.	Stewart: State failed to prove he was the shooter or a principal.	No; principal liability sufficed. 10
Was specific intent to kill shown? 11	State: multiple gunshots and surrounding conduct showed specific intent.	Stewart: intent was not proven beyond a reasonable doubt.	Yes; multiple shots and conduct supported specific intent. 12

Jackson v. Virginia, 443 U.S. 307 (U.S. 1979) (due process sufficiency standard asks whether any rational trier of fact could find guilt beyond a reasonable doubt 13)
State v. Mathews, 375 So. 2d 1165 (La. 1979) (Louisiana adopted Jackson sufficiency review 14)
State v. Abercrombie, 375 So. 2d 1170 (La. 1979) (Louisiana sufficiency review follows Jackson 15)
State v. Thompson, 233 So. 3d 529 (La. 2017) (reviewing court may not reweigh evidence or substitute its fact view 16)
State v. Burnette, 353 So. 2d 989 (La. 1977) (witness intimidation may show consciousness of guilt 17)
State v. Peterson, 290 So. 2d 307 (La. 1974) (principal liability need not be specifically denominated in the charging instrument 18)
State v. Massey, 91 So. 3d 453 (La. App. 5 Cir. 2012) (a defendant may be convicted as a principal even if he did not fire the fatal shot 19)
State v. Savoy, 931 So. 2d 1207 (La. App. 3 Cir. 2006) (principal liability supports second degree murder without proof defendant was the actual shooter 20)
State v. Tate, 851 So. 2d 921 (La. 2003) (specific intent conviction upheld where State proved principal participation and intent 21)
State v. Graham, 420 So. 2d 1126 (La. 1982) (specific intent is a state of mind inferred from circumstances 22)