165 So. 3d 978
La. Ct. App.2014Background
- Hughes was indicted for second‑degree murder of Williams and attempted second‑degree murder of Petty; trial in Sept. 2013 led to guilty verdicts on both counts.
- The State presented eyewitnesses (Petty, Williams’s mother Barbara Williams, M.H., Lagarde) and experts (Dr. Troxclair, Rauch) supporting guilt; the defense proffered alibi and self‑defense evidence.
- The defense argued Williams threatened Hughes previously and that Hughes acted in self‑defense; the State contended Hughes lacked a reasonable belief of imminent danger and used deadly force to kill.
- The jury was instructed on self‑defense, and the State was required to negate self‑defense beyond a reasonable doubt; credibility of witnesses was for the jury to decide.
- Hughes received life imprisonment for second‑degree murder and 50 years for attempted second‑degree murder, with sentences ordered concurrent; the court remanded for correction of the Uniform Commitment Order date.
- The appellate court affirmed the convictions and sentences, but remanded for correction of the commitment paperwork to reflect the correct offense date of January 2, 2012.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of evidence and self‑defense | Hughes acted in self‑defense; State failed to negate self‑defense. | State did not prove lack of self‑defense beyond a reasonable doubt. | Evidence supports State’s negation of self‑defense; convictions affirmed. |
| Excessive sentences | Sentences are grossly disproportionate if self‑defense is proven. | Mandatory life term plus 50 years is excessive given circumstances. | Sentences not unconstitutional; within statutory limits and justified by record. |
| Errors patent—Uniform Commitment Order date | Inaccurate offense date on commitment order. | Remand unnecessary. | Remand for correction of the Uniform Commitment Order date. |
Key Cases Cited
- State v. Durand, 963 So.2d 1028 (La.App.5th Cir. 2007) (illustrates specific‑intent standard for second‑degree murder)
- State v. Hoffman, 768 So.2d 542 (La.2000) (specific intent to kill may be inferred from firing at a person)
- State v. Batiste, 958 So.2d 24 (La.App.5th Cir. 2007) (supports inference of specific intent in murder cases)
- State v. Reed, 88 So.3d 601 (La.App.5th Cir. 2012) (sets burden on State to negate self‑defense in homicide)
- State v. Sinceno, 99 So.3d 712 (La.App.5th Cir. 2012) (describes two‑fold test for self‑defense in appellate review)
- State v. Vedol, 113 So.3d 1119 (La.App.5th Cir. 2013) (discusses review of mandatory minimum sentences for excessiveness)
- State v. Ross, 142 So.3d 327 (La.App.5th Cir. 2014) (guides excessiveness review and discretion in sentencing)