State v. Raye, 230 So. 3d 659

Defendant Clifton Raye (biological father) was indicted on five counts alleging repeated sexual abuse of his daughter C.R. beginning when she was 11 and continuing through age 13. Charges: two counts of aggravated rape (one oral, one penile-vaginal/anal), sexual battery (victim <13), sexual battery (victim <15), and oral sexual battery (victim <15).
C.R. (16 at trial) testified in detail about multiple incidents of oral sex, vaginal and anal penetration, digital anal penetration, forced masturbation, and frequency; a recorded Children’s Advocacy Center interview and testimony of family members supported disclosure timeline.
No physical or medical corroboration was found; forensic nurse noted normal exam but explained that normal findings do not rule out past penetration and delayed disclosure is common.
Defendant denied the allegations and claimed accusations were fabricated by step-daughters.
After a bench trial the judge convicted on all counts; sentences included life imprisonment on each aggravated rape count and concurrent lengthy terms on other counts. On appeal defendant challenged sufficiency of the evidence; the court affirmed and remanded for correction of patent errors (missing sex‑offender registration notice, UCO date formatting, failure to advise on post‑conviction prescription).

Issue	State's Argument	Raye's Argument	Held
Sufficiency of evidence to support convictions	C.R.’s testimony and CAC interview, viewed in the light most favorable to prosecution, established all elements beyond a reasonable doubt	Testimony lacked specific dates and there was no corroborating physical evidence, so it was insufficient	Affirmed: victim’s consistent, detailed testimony and CAC interview were sufficient under Jackson standard; lack of dates or physical evidence did not render testimony insufficient
Permissibility of convicting on single witness testimony in sex‑abuse case	A single credible victim’s testimony can suffice absent internal contradictions	Argued victim should not be believed without corroboration	Held: factfinder may credit victim; appellate court will not reweigh credibility; single witness sufficient if believed
Necessity of medical/physical corroboration	Not required; courts have upheld convictions without medical evidence	Relied on absence of corroboration to attack sufficiency	Rejected: prior precedents permit conviction on uncorroborated testimony in sexual‑abuse cases
Errors patent (notification and paperwork)	N/A (court raised remedial errors)	N/A	Remanded for written sex‑offender registration/notification using statutorily required form, correction of UCO offense‑date formatting, and advisement re: 2‑year PCR prescription in opinion

Jackson v. Virginia, 443 U.S. 307 (standard for sufficiency of the evidence)
State v. Neal, 796 So.2d 649 (La. 2001) (application of Jackson in Louisiana)
State v. Caffrey, 15 So.3d 198 (5th Cir. La. 2009) (deference to factfinder’s credibility determinations)
State v. Hernandez, 177 So.3d 342 (La. App. 5th Cir. 2015) (convictions can be upheld without medical corroboration)
State v. Mazique, 40 So.3d 224 (La. App. 5th Cir. 2010) (in long‑running abuse, exact dates often unavailable)
State v. Alfaro, 128 So.3d 515 (La. App. 5th Cir. 2013) (appellate court will not second‑guess factfinder’s credibility choices)