State v. Matthews, 200 So. 3d 895

Background

On Nov. 7, 2014 defendant Randall Glenn Matthews assaulted Emmett Stroud in the parking lot of Matthews’ pawn shop; Matthews retrieved a shovel and struck Stroud and his van. Police were called and a search warrant was obtained for the shop’s surveillance recordings.
Police found disconnected wiring where cameras should be; surveillance equipment was missing. Matthews told officers the system was not working and that employees were told not to let anyone into the shop. The video recording was not produced to police until March 2015.
Matthews was billed for aggravated battery (later reduced to simple battery by the jury) and, later, obstruction of justice for withholding the surveillance recording. The charges were tried jointly; Matthews sought severance and new counsel on the obstruction count, which the court denied.
The jury convicted Matthews of simple battery and obstruction of justice. He received concurrent/judicially-sequenced sentences: six months for battery and 18 months hard labor (to run consecutively) for obstruction.
Matthews moved for a new trial alleging threats against his counsel and improper subpoenaing; the trial court denied the motion. Matthews appealed.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence for obstruction of justice	State: circumstantial + direct statements show Matthews knew recordings would affect investigation, removed/withheld equipment, and intended to distort probe	Matthews: police may have overlooked equipment during search; he was at hospital when search occurred; he later cooperated by turning over video	Conviction affirmed — evidence (direct and circumstantial) sufficient; jury could reject innocent hypothesis and infer intent and concealment
Denial of severance / conflict-free counsel / new trial based on threats/subpoena of defense counsel	State: offenses arose from same incident; trial court granted continuance; no prejudice shown	Matthews: prosecutor threatened counsel with obstruction prosecution and subpoenaed him, creating unwaivable conflict and denying conflict-free counsel	Affirmed — trial court did not abuse discretion; evidence of threats/subpoena was not newly discovered, counsel was not forced to testify, and defendant had opportunity to retain new counsel
Jury instruction on obstruction (alleged temporal element)	Matthews: instruction added that defendant withheld recordings "for a period of time," adding an extra element and confusing jury; error was not harmless	State: no contemporaneous objection (except to phrase "search warrant"); any phrasing was superfluous and harmless given sufficiency	Affirmed — no reversible error; phrase did not add an element and, even if erroneous, was harmless in light of evidence

Key Cases Cited

Hudson v. Louisiana, 450 U.S. 40 (1981) (appellate protocol — address sufficiency first)
Jackson v. Virginia, 443 U.S. 307 (1979) (standard for reviewing sufficiency of the evidence)
State v. Captville, 448 So.2d 676 (La. 1984) (circumstantial-evidence rule and rejection of defendant’s hypothesis)
State v. Jones, 983 So.2d 95 (La. 2008) (knowledge requirement for obstruction of justice; knowledge that act may affect a proceeding is sufficient)
State v. Bell, 53 So.3d 437 (La. 2010) (standards for newly discovered evidence and new trial)
State v. Williamson, 389 So.2d 1328 (La. 1980) (jury-charge errors that violate due process may be reviewed despite lack of contemporaneous objection)
State v. Green, 493 So.2d 588 (La. 1986) (due process exception to contemporaneous objection rule for substantial rights)
State v. Hongo, 706 So.2d 419 (La. 1997) (harmlessness test for erroneous jury instructions)