State v. Roy, 177 So. 3d 1103

Defendant Barry Roy, the live-in boyfriend of the victims’ mother, was tried and convicted by a jury of two counts of molestation of a juvenile (La. R.S. 14:81.2) involving victims A.B. and C.A., both under seventeen when abuse occurred.
Victims testified Roy engaged in vaginal and oral sexual acts with them over a roughly two-year period while living in the household; one incident involved all three (a threesome).
Both victims described Roy as a father-figure who exercised emotional influence; incidents occurred in the home while he lived there and sometimes when the mother was absent or asleep.
Mother (defense witness) acknowledged Roy lived with them and later said she believed her daughters after they reported details; she described a time seeing Roy and C.A. in a bedroom in a manner she found suspicious.
Defendant challenged the sufficiency of evidence on appeal, arguing (1) the State failed to prove he had control or supervision over the victims and (2) the victims fabricated accusations.
The appellate court affirmed convictions, concluding the evidence (victim testimony and contextual facts showing emotional/father-figure influence and live-in status) sufficed to prove supervision/control and rejected the fabrication argument.

Issue	State's Argument	Roy's Argument	Held
Whether evidence proved Roy had "supervision or control" over victims for La. R.S. 14:81.2	Roy was a live-in boyfriend who acted as a father-figure and exercised emotional influence; incidents occurred in the home while he lived there	Insufficient proof: no testimony from mother that Roy supervised or controlled the children; only victims testified to perceived father-figure status	Affirmed: live-in status, father-figure behavior, emotional control and incidents in home satisfied supervision/control element
Whether victims fabricated allegations / insufficiency based on credibility	Victim testimony (both) describing repeated sexual abuse, corroborating details, and mother’s eventual belief supported conviction	Victims invented claims; their credibility undermined by mental health issues and alleged motives	Affirmed: jury weighed credibility, no irreconcilable contradictions or conflict with physical evidence; one witness’s credible testimony can support verdict

Jackson v. Virginia, 443 U.S. 307 (establishes standard for sufficiency review)
State v. Leger, 936 So.2d 108 (reiterates Jackson standard under Louisiana law)
State v. Captville, 448 So.2d 676 (discusses appellate deference to jury credibility determinations)
State v. Anderson, 91 So.3d 1080 (live-in or position-of-influence can establish supervision/control)
State v. Davis, 108 So.3d 833 (live-in boyfriend/relative status sufficient for control element)
State v. Mussall, 523 So.2d 1305 (appellate impingement on factfinder’s role limited to due-process concerns)