State v. Cooley, 92 So. 3d 1095

Cooley was convicted of second-degree murder and sentenced to life without benefits after a pawn-shop killing in Shreveport on June 13, 2008; surveillance video and police evidence tied him to the crime and weapon.
Prior robberies in the same area (Family Dollar and Texaco) involved Cooley and produced physical evidence (a stolen Cadillac, fingerprints) and eyewitness identifications.
A cousin, Tiray Edwards, provided a post-Miranda statement detailing Cooley’s involvement in all three incidents.
Officer investigations linked latent prints from the Cadillac to Cooley; a .44-caliber Rossi revolver found in his closet matched the autopsy bullet.
The state gave 404(B) notice to use other-crimes evidence; Prieur hearing occurred; the court deemed the Texaco and Family Dollar robberies admissible as res gestae or purposeful antecedent evidence; Cooley’s jury found him guilty; life sentence imposed; appeal followed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admissibility of other-crimes evidence under 404(B)	Cooley argues 404(B) evidence was irrelevant and prejudicial	State contends Texaco res gestae and Family Dollar as admissible to show plan/intent or to counter self-defense	Admitted, harmless error; overall guilt not affected by the evidence

State v. Odenbaugh, 82 So.3d 215 (La. 2011) (404(B) and res gestae analysis; harmless error standard applied)
State v. Scales, 655 So.2d 1326 (La. 1995) (trial court has wide discretion on relevancy of other-crimes evidence)
State v. Cooks, 833 So.2d 1034 (La. App. 2d Cir. 2002) (admission of other-crimes evidence reviewed for abuse of discretion)
State v. Prieur, 277 So.2d 126 (La. 1973) (standards for evidence of other crimes; precursor to 404(B) framework)