69 So. 3d 538
La. Ct. App.2011Background
- Davis was convicted of second degree murder for stabbing Joe Lee Jones; conviction affirmed on appeal.
- Jones, a 66-year-old man, was found murdered after being seen with Davis at a coworking location and later in Jones's truck.
- Surveillance video and witnesses place Davis with Jones; Davis later washed himself and attempted to hide evidence.
- The State's evidence showed extensive injuries to Jones and little to no injuries to Davis; multiple items matched victim's DNA.
- Davis gave inconsistent statements about the events, including self-defense claims, and moved the body after Jones's death.
- Davis was sentenced to life imprisonment without parole and ordered to pay restitution; motion for post-verdict judgment of acquittal denied.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of evidence to negate self-defense | Davis claims self-defense invalidates guilt | State fails to disprove self-defense | Conviction affirmed; evidence supports no self-defense |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (1979) (standard for sufficiency of the evidence review)
- State v. Tate, 851 So.2d 921 (La. 2003) (clarifies sufficiency review approach)
- State v. Carter, 974 So.2d 181 (La. App. 2d Cir. 2008) (reaffirms deference to jury credibility)
- State v. Matthews, 464 So.2d 298 (La.1985) (self-defense sufficiency framework)
- State v. Palmer, 57 So.3d 1099 (La. App. 2d Cir. 2011) (requires viewing evidence in the light most favorable to the state)
- State v. Eason, 3 So.3d 685 (La. App. 2d Cir. 2009) (credibility and evidentiary weight given to jury)
- State v. Hill, 956 So.2d 758 (La. App. 2d Cir. 2007) (jury credibility determination afforded deference)