State v. Bryant, 101 So. 3d 429

Goetz, at home with his two-year-old daughter, observed a man outside his back French doors and then heard the doors kicked in.
The shooter stood on a step outside the doorway, fired twice, then fled; Goetz did not testify that the intruder entered the home.
Bryant was identified as the shooter by Goetz and was charged with two counts of simple burglary and one count of aggravated burglary related to the Goetz residence.
Trial proceeded without a jury trial; the court convicted Bryant of aggravated burglary and a separate simple burglary; Bryant appealed, challenging sufficiency of entry proof.
The court of appeal reversed the aggravated burglary conviction, holding no direct entry was shown since Goetz did not testify that Bryant crossed the threshold.
The Louisiana Supreme Court granted review to decide whether entry occurred under burglary law when an intruder kicks in a door and fires from the threshold.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Is entry proven when any part crosses the threshold?	State argues threshold crossing suffices; Goetz’s lay testimony misled by asking about actual entry.	Bryant argues no entry proven; Goetz testified no part crossed the threshold, no direct evidence of entry.	Entry occurs when any part crosses the plane of the threshold; court sustains conviction.
Whether Jackson v. Virginia standard requires more than threshold-crossing proof.	State contends sufficiency under Jackson supports entry based on inference from kicking and firing.	Bryant argues the record lacks direct/ circumstantial proof of crossing the threshold beyond reasonable doubt.	Evidence viewed in light of Jackson v. Virginia is sufficient to prove entry beyond a reasonable doubt.
Can the trial court reasonably infer entry from Goetz’s demonstrations and surrounding evidence?	State contends demonstrations plus human experience support inference of entry.	Bryant contends there is no circumstantial evidence proving threshold crossing beyond reasonable doubt.	Yes; the trial court could reasonably infer entry from the kick and the arm extension firing from the threshold.

State v. Tate, 851 So.2d 921 (La. 2003) (Jackson v. Virginia standard for sufficiency of evidence)
State v. Captville, 448 So.2d 676 (La. 1984) (establishes standard for sufficiency review)
State v. Abrams, 527 So.2d 1057 (La. App. 1 Cir. 1988) (entry inferred when defendant’s person intrudes into structure)
State v. Hogan, 753 So.2d 965 (La. App. 2 Cir. 2000) (entry defined in burglary context)
State v. Jefferson, 759 So.2d 1016 (La. App. 2 Cir. 2000) (entry discussed in burglary context)
Paulley v. Commonwealth of Kentucky, 323 S.W.3d 715 (Ky. 2010) (brief entry sufficient when door ajar and foot crosses threshold)
Hebron v. State, 331 Md. 219 (Md. 1993) (circumstantial evidence may justify inferring entry)
State v. Pace, 602 N.W.2d 764 (Iowa 1999) (entry includes breaking the plane of the threshold)
People v. Roldan, 100 Ill.App.2d 81 (Ill. App. 1968) (entry demonstrated by kicking the window/entry points)