State v. Patterson
63 So. 3d 140
La. Ct. App.2011Background
- Patterson was indicted for second degree murder under La. R.S. 14:30.1 on Oct. 20, 2005; he pled not guilty.
- A Motion to Suppress Statement was denied after a hearing on March 23, 2007.
- Defendant was tried on Nov. 17–18, 2009; a twelve-member jury convicted him of second degree murder.
- A Motion for a New Trial was denied; Patterson was sentenced to life imprisonment without parole, probation, or suspension; notice of appeal filed and appeal granted.
- The homicide occurred July 19, 2005, in a Jefferson Parish apartment complex; Tyrone Kayron Temple died from multiple gunshot wounds; evidence included a white car, shell casings, and blood in the vehicle.
- Defendant gave a taped custodial statement admitting the shooting and testified at trial; the State presented evidence of prior robbery by the victim and flight/disposal of the weapon.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of evidence on self-defense | Patterson argues the evidence shows self-defense; the State failed to prove non-self-defense beyond a reasonable doubt. | Patterson contends the killing was justifiable self-defense given prior robberies by Temple and fear for life. | No; the State negated self-defense beyond a reasonable doubt. |
| Sufficiency of evidence for second degree murder vs. manslaughter | Patterson asserts the evidence supports manslaughter due to sudden passion/heat of blood. | The State argues the jury could find specific intent to kill or inflict great bodily harm beyond reasonable doubt, negating manslaughter. | Evidence supports second degree murder; mitigatory factors not proven by preponderance. |
| Patents errors: sentencing delay and commitment advisal | No explicit waiver of the 24-hour sentencing delay; potential prejudice by premature sentencing. | Delay was mandatory; any prejudice is lacking; no remand required. | No prejudice shown; conviction and life sentence affirmed; remand for commitment advisal corrected. |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (U.S. Supreme Court 1979) (sufficiency review—any rational trier could find guilt beyond reasonable doubt)
- State v. Brown, 414 So.2d 726 (La. 1982) (state bears burden to negate self-defense beyond reasonable doubt)
- State v. Theriot, 963 So.2d 1012 (La. App. 5 Cir. 2007) (two-step test for self-defense and credibility determinations by jury)
- State v. Dressner, 45 So.3d 127 (La. 2010) (provocation and reduction of homicide to manslaughter; burden on defendant)
- State v. Arabie, 496 So.2d 554 (La. App. 1 Cir. 1986) (recall that revenge does not justify killing, even with provocation)