247 So. 3d 981
La. Ct. App.2018Background
- On July 17–18, 2016, Kevin White was shot in the face, transported to University Health Hospital, and died the next day from a close‑range gunshot wound.
- Multiple eyewitnesses (Brandon Hanson, Carlzays Hanson, Denise Hill, Arthur Sloan) placed Labroderick Alexander at the scene with a firearm and testified they heard/observed an argument immediately before a single gunshot; several witnesses identified Alexander in court.
- Physical evidence included a spent cartridge casing, blood spatter at the scene and in a white SUV, and a deformed bullet fragment removed from White; autopsy by Dr. Long Jin established a close‑range facial gunshot caused the fatal injury.
- Texts and calls corroborated escalating confrontation: White texted that Alexander had pointed a gun at him shortly before being shot; White’s sister received an anonymous tip naming "B" as the shooter.
- Alexander declined to testify. A jury found him guilty of second‑degree murder (11–1 verdict). The trial court sentenced him to mandatory life at hard labor without parole, probation, or suspension of sentence. Alexander appealed, arguing insufficiency of the evidence and claiming self‑defense.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of evidence to convict of second‑degree murder | State: eyewitnesses, forensic evidence, and victim’s injury support that Alexander shot White with specific intent to kill or inflict great bodily harm | Alexander: evidence insufficient to prove he was the shooter and that he had requisite specific intent | Affirmed — viewing evidence in light most favorable to prosecution, a rational trier of fact could find all elements proven beyond a reasonable doubt |
| Self‑defense claim | N/A (prosecution argues self‑defense not established) | Alexander: acted in self‑defense after White punched him | Rejected — witnesses showed Alexander was the initial aggressor, was armed, did not retreat, and shooting at close range was not reasonably necessary; State proved the homicide was not in self‑defense |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (standard for sufficiency review requires that any rational trier of fact could find guilt beyond a reasonable doubt)
- State v. Lloyd, 161 So.3d 879 (discharge of firearm at close range aimed at a person is indicative of specific intent to kill or inflict great bodily harm)
- State v. Walker, 221 So.3d 951 (specific intent may be inferred from circumstances and conduct)
- State v. Washington, 188 So.3d 350 (specific intent can be formed instantly and sufficiency review deferential to jury credibility findings)
- State v. Edwards, 162 So.3d 512 (State bears burden to prove homicide was not in self‑defense when defendant claims justification)
