244 So. 3d 629
La. Ct. App.2017Background
- Defendant Nathaniel M. Mingo shot and killed his girlfriend Amanda Collins on March 15, 2015; Collins died of a single, close‑range 9mm gunshot wound to the neck.
- Surveillance and witness evidence placed the couple at a casino that night; an elevator video showed Mingo pushing Collins during an argument; Collins was intoxicated and had methamphetamine in her system.
- Mingo admitted drinking tequila and taking two Xanax pills, later told others he had killed Collins, attempted to dispose of the body (barrel/chainsaw and trash bags found), and was later found with Collins’ ID, cash, and a 9mm handgun.
- Forensics tied Mingo to the gun and to blood on clothing; a firearms examiner testified the pistol required trigger pressure and was unlikely to fire accidentally.
- Mingo was tried for second‑degree murder, claimed an affirmative defense of voluntary intoxication, was convicted by a jury, sentenced to life without parole, and appealed arguing (1) intoxication negated specific intent, (2) denial of self‑representation, and (3) denial of voir dire rights.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of evidence / intoxication defense | State: Evidence showed specific intent to kill; intoxication not proved by preponderance; state negated it beyond a reasonable doubt | Mingo: Voluntary intoxication (alcohol + Xanax) prevented formation of specific intent required for second‑degree murder | Court: Affirmed conviction — jury reasonably found intoxication insufficient and specific intent proven beyond reasonable doubt |
| Right to self‑representation | State: Late, last‑minute request; concerns about mental health, education, and competency justified denial | Mingo: Made an unequivocal request to waive counsel and represent himself minutes before voir dire | Court: Denial proper under Faretta — trial court did not abuse discretion given timing and competency concerns |
| Voir dire rights | State: Mingo was afforded full constitutional voir dire through counsel; no requirement for individual voir dire | Mingo: Sought to personally question jurors or have individual voir dire | Court: Motion moot after denial of self‑representation; no constitutional violation — voir dire rights preserved |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (1979) (standard for appellate review of sufficiency of the evidence)
- Faretta v. California, 422 U.S. 806 (1975) (right to self‑representation and requirements for a knowing waiver of counsel)
- Gideon v. Wainwright, 372 U.S. 335 (1963) (right to counsel in criminal proceedings)
- McKaskle v. Wiggins, 465 U.S. 168 (1984) (structural error analysis for denial of self‑representation)
- Adams v. United States, 317 U.S. 269 (1942) (courts must ensure a defendant knows the dangers of self‑representation)