State v. Jackson, 265 So. 3d 928

Defendant Kenneth Jackson was indicted for second-degree murder after stabbing Vanessa Jackson’s son, Brandon King, who died from three stab wounds; jury trial was a bench trial resulting in conviction and life sentence without parole.
Officers found the defendant standing over the victim with a large bloody knife; defendant tossed the knife and was subdued and arrested; victim’s body was about 17 feet from the doorway on the yard.
Defendant gave a recorded post-arrest statement claiming he picked up a knife to scare the victim off during a physical confrontation and later admitted stabbing him; at trial he claimed self-defense, saying the victim "bum-rushed" him after entering the home.
State evidence included witness testimony (Vanessa and others), police observations (no signs of a struggle inside, knife block upright, defensive wound on victim’s forearm), and testimony about the defendant’s aggressive demeanor at the scene.
The State introduced prior-act evidence that two years earlier the defendant had held a gun to the victim’s head and threatened him; trial court admitted the evidence over defendant’s motion in limine.
On appeal defendant challenged (1) admission of other-crimes evidence under La. C.E. art. 404(B) and (2) sufficiency of the evidence to disprove self-defense; the appellate court affirmed conviction and sentence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of the evidence / self-defense	State: Evidence supports that defendant was aggressor; injuries, scene, witness accounts, and defendant’s inconsistent statements permit finding beyond reasonable doubt he did not act in self-defense	Jackson: He acted in self-defense inside his home after the victim forced entry, bum-rushed and tried to seize his knife; fatal blows occurred in struggle	Held: Affirmed. Viewing evidence in light most favorable to prosecution, rational trier of fact could reject self-defense and find second-degree murder proven beyond reasonable doubt
Admission of other-crimes evidence (404(B))	State: Prior threats/weapon use toward victim are independently relevant to intent, motive, and absence of mistake; probative value outweighs prejudice	Jackson: Prior incident was remote, factually different, not probative of motive/intent for this killing; admission was unfairly prejudicial	Held: Affirmed. Trial court did not abuse discretion; prior threats were relevant to intent/motive and not unduly prejudicial

Hudson v. Louisiana, 450 U.S. 40 (U.S. 1981) (standard for acquittal when evidence insufficient)
Jackson v. Virginia, 443 U.S. 307 (U.S. 1979) (Jackson standard for reviewing sufficiency of the evidence)
State v. Ordodi, 946 So.2d 654 (La. 2006) (appellate review of sufficiency and deference to factfinder)
State v. Hearold, 603 So.2d 731 (La. 1992) (circumstantial-evidence test guidance)
State v. Captville, 448 So.2d 676 (La. 1984) (rejecting defendant's hypothesis when factfinder discredits it)
State v. Garcia, 108 So.3d 1 (La. 2012) (gatekeeping and abuse-of-discretion standard for 404(B) evidence)
State v. McArthur, 719 So.2d 1037 (La. 1998) (limits on other-crimes evidence for motive)
State v. Prieur, 277 So.2d 126 (La. 1973) (notice and proof requirements for prior-bad-act evidence)
State v. Williams, 804 So.2d 932 (La. App.) (State must disprove self-defense beyond reasonable doubt)
State v. Maten, 899 So.2d 711 (La. App.) (specific intent to kill may be inferred from use of deadly weapon)
State v. Brunet, 674 So.2d 344 (La. App.) (deadly-weapon use supports inference of intent to kill)
State v. Calloway, 1 So.3d 417 (La. 2009) (appellate courts should not substitute their view for the factfinder on credibility)