167 So. 3d 31
La. Ct. App.2014Background
- Griffin was convicted of second-degree murder of Crayton and attempted possession of a firearm by a convicted felon; sentenced to life without parole and 7.5 years, with sentences running concurrently and consecutively to other sentences, plus a $500 fine and costs.
- Crayton’s death resulted from two gunshots after a struggle over a gun; Williams and Noel testified Griffin fired the fatal shot after Crayton knocked the gun from Griffin.
- Griffin challenged the conviction on multiple grounds, including self-defense and constitutional challenges to 14:95.1, as well as various trial- and voir dire-related issues.
- The court affirmed Griffin’s convictions and sentences and remanded for correction of the commitment order.
- The case involved retroactivity of the 2012 constitutional amendment to Article I, § 11, and scrutiny of juror challenges and ineffective assistance claims, all within direct appeals.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Self-defense sufficiency in second-degree murder | State argued Griffin had no reasonable belief of imminent danger | Griffin claimed Crayton threatened him and that retreat was not feasible | Sufficiency supported: State negated Griffin’s self-defense beyond reasonable doubt. |
| Constitutionality/retroactivity of La. R.S. 14:95.1 | Amendment retroactivity potentially affects validity | Statute unconstitutional post-amendment (argued broader rights restriction) | Not meriting relief; 14:95.1 upheld and retroactivity applied under Draughter and Eberhardt. |
| Challenge for cause to juror Allen Dyess | Dyess was not impartial due to law-enforcement connections | Judge should have granted challenge for cause | Abuse of discretion not shown; denial affirmed and peremptories exhausted. |
| Ineffective assistance of counsel (pro se claims) | Counsel failed in multiple respects (motions, voir dire, cross-examination) | Counsel’s actions were trial strategy; no prejudice shown | No merit; claims rejected after Strickland analysis oriented to record. |
| Errors patent/remand for commitment correction | Uniform Commitment Order mis-stated sentencing date | Not a material error requiring different outcome | Remanded for correction of the commitment order. |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (U.S. 1979) (sufficiency standard for proof beyond a reasonable doubt; reasonable jury view of evidence)
- State v. Durand, 963 So.2d 1028 (La. App. 5 Cir. 2007) (circumstantial/identity and intent considerations in sufficiency)
- State v. Hoffman, 768 So.2d 542 (La. 2000) (inference of specific intent from act of shooting)
- State v. Sparkman, 136 So.3d 98 (La. App. 5 Cir. 2014) (relevant to self-defense and aggressor doctrine considerations)
- Draughter, 130 So.3d 855 (La. 2013) (constitutional amendment § 11 retroactivity and effect on firearm restrictions)
- State v. Williams, 138 So.3d 727 (La. App. 5 Cir. 2014) (retroactivity application after amendment to Article I, § 11)
- State v. Eberhardt, 145 So.3d 377 (La. 2014) (upheld constitutionality of 14:95.1 and its tailoring to public safety)
- State v. Monk, 315 So.2d 727 (La. 1975) (circumstantial evidence challenges for cause authority)
- State v. Gant, 942 So.2d 1099 (La. App. 5 Cir. 2006) (scope of challenges for cause and impartiality standards)
- State v. Hoffman, 768 So.2d 542 (La. 2000) (trial strategy and preservation of error)