State v. Collins
62 So. 3d 268
La. Ct. App.2011Background
- Cornell Coleman was murdered in October 1991 on the 2400 block of South Liberty Street, New Orleans.
- Christopher Collins was indicted for second degree murder on October 11, 2006; trial began October 6, 2009.
- Collins underwent repeated competency evaluations; the court found him competent to stand trial in 2007 and 2009.
- A confession from Collins was introduced at trial, detailing a 1994–1995 shooting at the First and South Liberty location.
- The defense challenged the sufficiency of the evidence, the denial of a new-trial motion, and the constitutionality of a non-unanimous verdict instruction.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the evidence proves specific intent to kill | Collins argues evidence fails to prove intent to kill or inflict great bodily harm. | Collins asserts his statement shows accidental discharge during a struggle; no witness corroborates the killing. | Yes, evidence supports specific intent; circumstantial and statement corroborate intent. |
| Corpus delicti requirement and corroboration of confession | Martín corpus delicti requires corroboration of the crime independent of the statement. | Confession alone cannot prove corpus delicti. | Corroboration exists; elements like head wound, location, victim identity, and unloaded weapon establish the crime. |
| Denial of motion for new trial under Article 851(1) | A sufficiency challenge warrants reversal if verdict is unsupported. | Trial court erred in denying new trial; verdict contrary to law and evidence. | No abuse of discretion; evidence supports verdict. |
| Constitutionality of non-unanimous verdict instruction | Non-unanimous verdicts are unconstitutional. | Non-unanimous verdicts authorized by Article 782(A) and no harm shown due to lack of polling. | Assignment of error meritless; procedural bar and lack of showing harm. |
Key Cases Cited
- State v. Martin, 645 So.2d 190 (La. 1994) (corpus delicti corroboration required to prove crime via independent evidence)
- Jackson v. Virginia, 443 U.S. 307 (U.S. 1979) (sufficiency review: proof beyond a reasonable doubt)
- State v. Rosiere, 488 So.2d 965 (La. 1986) (circumstantial-evidence standard for conviction)
- State v. Hebert, 787 So.2d 1041 (La. App. 4th Cir. 2001) (inference of specific intent from circumstances)
- State v. Thibodeaux, 750 So.2d 916 (La. 1999) (corroboration scope under Martin clarified)
- State v. Guillory, 45 So.3d 612 (La. 2010) (art. 851(5) new-trial review as a question of law; abuse of discretion standard clarified)
- State v. Gray, 351 So.2d 448 (La. 1977) (new-trial denial reviewed for abuse of discretion; proof limits)
- State v. Bertrand, 6 So.3d 738 (La. 2009) (procedural bar on non-unanimous verdict challenges; standing harm requirement)