State v. Jones, 165 So. 3d 74

Willie Jones was indicted for second-degree murder in Jefferson Parish; trial held March 14–15, 2012 with a jury; pretrial motions including suppression denied; State sought and obtained a Motion in Limine to exclude victim’s character/other crimes and the court granted it; extensive trial testimony about the shooting, witness identifications, and recovered weapons; Jones convicted and sentenced to life without parole in 2012 when he was 17; appellate briefing occurred with remand for Miller v. Alabama considerations; court affirms conviction, vacates parole-ineligibility portion, and remands for resentencing consistent with Miller.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence for second-degree murder	State proves specific intent or enumerated felony.	Jones acted in self-defense; insufficient evidence of intent to kill.	Sufficient evidence of specific intent; self-defense rejected.
Admission of victim’s prior convictions / hostile act requirement	Defense sought victim’s rap sheet to show danger; evidence of overt act present.	Overt act shown by victim’s conduct; rap sheet admissible to support self-defense.	Overt act not established; trial court proper in excluding prior-convictions evidence.
Propriety of sentencing under Miller v. Alabama	Sentence permissible; Miller not retroactive to require relief.	Mandatory life without parole for juvenile unconstitutional; require mitigation.	Remand for Miller-compliant sentencing; vacate parole-ineligibility portion.
Impact of trial court rulings on sufficiency/ebecs of verdict	Evidence viewed for sufficiency; no reversible error in post-verdict rulings.	Trial court erred in rulings that affected the outcome.	No reversible error; conviction affirmed and remand for resentencing.

State v. Gonzalez, 975 So.2d 3 (La.App. 5 Cir. 2007) (specific-intent can be inferred from the circumstances and use of a deadly weapon)
State v. Theriot, 963 So.2d 1012 (La.App. 5 Cir. 2007) (two-fold inquiry for self-defense; reasonable belief and necessity of deadly force)
State v. Lee, 331 So.2d 455 (La.1975) (overt-act requirement for admission of victim’s dangerous character)
State v. Jones, 748 So.2d 1176 (La.App. 5 Cir. 1999) (definition of overt act as present intention to kill or harm by victim)
State v. Wallace, 788 So.2d 578 (La.App. 5 Cir. 2001) (credibility determinations and sufficiency review)
Miller v. Alabama, 132 S. Ct. 2455 (U.S. 2012) (mandatory life without parole for juveniles requires consideration of youth mitigating factors)
State v. Landry, 106 So.3d 106 (La. 2013) (remand for Miller-based resentencing after retroactivity analysis)