State v. Howard, 182 So. 3d 360

Defendant Joseph Howard was charged with attempted second-degree murder after a shooting on August 28, 2012; a jury convicted him of the responsive verdict of aggravated battery.
Trial testimony conflicted: State witnesses (victim Herman Triggs, his girlfriend Frenada Jack, and neighbor Keith Lewis) testified Howard approached, argued with Triggs, and shot him as Triggs returned to his truck.
Howard testified he approached to buy drugs, Triggs allegedly pulled a gun and patted him down, a struggle ensued, the gun discharged, and he fled—claiming self-defense.
The jury rejected Howard’s self-defense claim and found him guilty of aggravated battery; he was sentenced to seven years at hard labor and later adjudicated a second felony offender (enhanced sentence remained seven years).
On appeal Howard challenged sufficiency of the evidence (claiming self-defense); the court reviewed the record under Jackson v. Virginia and affirmed conviction and sentence.
The appellate court found an error patent: the uniform commitment order listed the offense date incorrectly (September 18, 2012); the court remanded for correction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of the evidence to support aggravated battery conviction	State: testimony and identifications support that Howard intentionally used a dangerous weapon likely to cause great bodily harm	Howard: he acted in self-defense; the shooting occurred during a struggle after Triggs allegedly pulled a gun	Affirmed — viewed in the light most favorable to prosecution, evidence was sufficient and jury reasonably rejected self-defense

Jackson v. Virginia, 443 U.S. 307 (reviewing sufficiency of the evidence under due process)
State v. Smith, 661 So.2d 442 (La. 1995) (appellate courts should not reassess witness credibility)
State v. Rainey, 722 So.2d 1097 (La.App. 5 Cir.) (elements of aggravated battery defined)
State v. Oliveaux, 312 So.2d 337 (La. 1975) (requirement to review record for errors patent)