State v. Bradley, 272 So. 3d 94

Victims Kenneth and Lakeitha Joseph disappeared Feb 18, 2014; their bound, weighted bodies were later recovered from the Intracoastal Waterway and autopsies showed drowning and blunt trauma.
A silver Dodge Caravan belonging to a family member was found in Atlanta with large blood stains; DNA and other forensic leads connected the van to the victims.
Investigation led to arrests of Horatio Johnson, Brittany Martin, Frank Mike, Steven Bradley, and a fugitive, Amir “Blue” Ybarra; co-defendants Martin and Mike pleaded guilty to obstruction-related charges and testified at Bradley’s trial.
Testimony (Martin, Mike) placed Bradley at the studio when the victims were assaulted, moving and driving the van, participating in transporting and disposing of bodies, and directing cleanup and relocation of the van to hinder investigation.
Bradley was convicted by a jury of conspiracy to commit obstruction of justice (La. R.S. 14:26) and obstruction of justice by tampering with evidence in a homicide (La. R.S. 14:130.1); sentences of 15 and 35 years (concurrent) were imposed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence for conspiracy to obstruct justice	State: testimony and corroboration show agreement and overt acts to hide/destroy evidence	Bradley: evidence insufficient to prove he agreed to or aided a conspiracy to tamper with evidence	Court: Evidence (co-defendant testimony, van movement/cleanup/abandonment) viewed in State's favor suffices under Jackson v. Virginia; conviction affirmed
Excessiveness of sentences	State: sentences within statutory ranges and supported by harm and defendant’s criminal history	Bradley: sentences excessive given Article 894.1 and proportionality concerns	Court: Sentences not constitutionally excessive; record supports given brutality of murders, obstruction conduct, and criminal history; affirmed

Jackson v. Virginia, 443 U.S. 307 (U.S. 1979) (standard for reviewing sufficiency of the evidence)
State v. Mussall, 523 So. 2d 1305 (La. 1988) (deference to rational factfinder in Jackson review)
State v. Jones, 983 So. 2d 95 (La. 2008) (knowledge element for obstruction satisfied if act reasonably may affect a potential or future proceeding)
State v. Powell, 179 So. 3d 721 (La. App. 4 Cir. 2015) (intent requirement for tampering with evidence; movement suffices if intent and knowledge present)
State v. Leonard, 262 So. 3d 378 (La. App. 4 Cir. 2018) (single witness testimony, if believed, can support factual conclusion)