211 So. 3d 481
La. Ct. App.2017Background
- Two women (Angela Matte, Jackie Campbell) found badly burned in a trailer; evidence suggested they were dead before the fire and one had a wire around her neck. Cause of death undetermined; strangulation indicated.
- Defendant Daniel B. Prince was identified by a jailhouse informant (Michael Hayes) who testified Prince confessed to killing and burning the women; Hayes described details of sex, strangulation with an extension cord, theft of money, and ignition.
- Other evidence: two bar witnesses placed Defendant interacting with victims at the Little Easy; a silver truck (matching one Prince later drove and was arrested in as a stolen vehicle) was seen near the victims’ trailer; no DNA or direct physical evidence tied Prince to the scene.
- Procedural history: Prince indicted for two counts of first-degree murder (death-penalty sought); jury convicted on both counts (penalty phase deadlocked); Defendant sentenced to life. Multiple post-trial proceedings concerned an out-of-time appeal; convictions appealed to this court.
- Issues on appeal: (1) sufficiency of the evidence, (2) State’s opening/closing “evil” argument, (3) claim of Napue/Giglio due to alleged false or undisclosed benefits to informant Hayes, (4) trial court’s refusal to give requested “great caution” jury instruction for snitch testimony.
- Result: Appellate court affirmed convictions, vacated and remanded for resentencing to impose separate sentences on each murder count.
Issues
| Issue | State's Argument | Prince's Argument | Held |
|---|---|---|---|
| Sufficiency of evidence to support convictions | Hayes’ jailhouse confession plus corroborating facts (bar ID, truck seen, wire on victim) sufficed; jury believed Hayes | Case rests on a single informant; no DNA, inconsistencies in witness accounts, alternate suspect (Jason Fruge) and weak corroboration | Affirmed: viewing evidence in light most favorable to prosecution, a rational juror could find guilt beyond reasonable doubt (Jackson standard) |
| Improper prosecutorial argument (opening/closing "evil" theme) | Remarks were abstract, not targeted at defendant; court admonished and instructed jury to disregard emotion | Argument appealed to prejudice and fear; trial court erred in overruling objection | Overruled: any impropriety was harmless; instruction to jury and evidentiary centrality of Hayes’ testimony meant remarks did not clearly influence verdict |
| Napue/Giglio claim (State knowingly used false/undisclosed testimony re: Hayes’ benefits) | State did not solicit false testimony; Hayes’ credibility and any benefits were fully explored at trial | Hayes gave false/misleading testimony about prior convictions and parole dealings; State withheld impeachment material or failed to correct falsehoods | Denied: defendant failed to show Hayes’ testimony was actually false and that the prosecution knew of falsity; matters bearing on Hayes’ benefits were ventilated before jury |
| Refusal to give a "great caution" instruction for snitch/incentivized witness | Hayes’ testimony was materially corroborated (contacts at bar, truck seen, wire found) so special caution not required | Hayes’ testimony was largely uncorroborated on material points; informant received substantial benefits; jury should have been specially instructed to view snitch testimony with great caution | Denied: court’s credibility instruction was sufficient given corroboration; no abuse of discretion in declining special ‘‘great caution’’ charge (but Cooks, J., dissented) |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (standard for appellate review of sufficiency of the evidence)
- Napue v. Illinois, 360 U.S. 264 (prosecutorial use or allowance of false testimony requires reversal if material)
- Giglio v. United States, 405 U.S. 150 (prosecution must disclose deals or promises to witnesses affecting credibility)
- Kansas v. Ventris, 556 U.S. 586 (rewarded informant testimony may be inherently untrustworthy)
- State v. Castleberry, 758 So.2d 749 (La.) (accomplice/snitch testimony need not trigger special caution instruction when materially corroborated)
- State v. Kennerson, 695 So.2d 1367 (La. App.) (reciting Jackson sufficiency standard)