State v. Ingram, 71 So. 3d 437

Ingram was convicted of manslaughter for shooting unarmed Kimberly Ingram in 2006 after a confrontation with his then-wife and his current wife present at the scene.
The trial produced conflicting testimony; Ingram challenged the verdict as not supported by sufficient evidence under self-defense theory.
The defense argued the killing was justified under La. R.S. 14:20(A)(4)(a) due to unlawful entry by Kim and Ingram’s belief that deadly force was necessary.
Disputed evidentiary issues arose: admission of a drug-test report via the pathologist, and an altered 911 transcript used at trial.
The court of appeal previously remanded for related issues; the Louisiana Supreme Court reversed and remanded for remaining assignments, which this court addresses.
The court ultimately affirmed the conviction and 28-year sentence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of the evidence for manslaughter	Ingram contends Kim unlawfully entered the dwelling, making deadly force presumptively reasonable.	Ingram argues the use of deadly force was justified and should negate the elements of manslaughter.	No; evidence supports a finding that the use of deadly force was unreasonable, sustaining manslaughter verdict.
Admissibility of drug test results without the analyst	State relied on a lab report not produced by the pathologist who testified.	Confrontation and reliability concerns require exclusion or reversal.	Harmless error; evidence not essential to offense and the verdict would be the same without it.
Altered 911 transcript without notice	State used an altered transcript to bolster its theory about invitations into the home.	Alteration violated professional duties and prejudiced Ingram.	Harmless; trial court allowed both versions and jurors reviewed the recording; admonition issued, but no reversal.
Unanimity of verdict	Non-unanimous verdicts for murder violate constitutional rights.	Louisiana's non-unanimous scheme is constitutional.	Constitutionality upheld; Behrand/ Bertrand controls this issue; verdicts deemed valid.
Excessiveness of sentence	28 years is excessive given provocation and circumstances.	Sentence properly considers factors under Art. 894.1 and is not disproportionate.	Within court’s discretion; not grossly disproportionate; affirmed.

Hudson v. Louisiana, 450 U.S. 40 (U.S. 1981) (sufficiency and due process in criminal trials; standard of review)
Jackson v. Virginia, 443 U.S. 307 (U.S. 1979) (sufficiency of the evidence standard)
Delaware v. Van Arsdall, 475 U.S. 673 (U.S. 1986) (harmless error analysis for evidentiary issues)
Melendez-Diaz v. Massachusetts, 129 S. Ct. 2527 (U.S. 2009) (confrontation clause; testimonial certificates require witness cross-examination)
State v. Bertrand, 6 So.3d 738 (La. 2009) (constitutional validity of non-unanimous murder verdicts in Louisiana)
State v. Davidson, 32 So.3d 290 (La. 2010) (harmless error framework; confrontation-related errors)
State v. Lanclos, 419 So.2d 475 (La. 1982) (sentence framework and Art. 894.1 considerations)
State v. Caruso, 733 So.2d 1169 (La. 1999) (presumptions in the criminal code and their effect)
State v. Brown, 414 So.2d 726 (La. 1982) (retreat doctrine and use of force in defense)
State v. Snedecor, 294 So.2d 207 (La. 1974) (transcripts accompanying recorded material admissibility)