State v. Smith, 90 So. 3d 1114

Smith convicted of second-degree murder after trial; sentenced to life without parole.
Competency hearings found her competent to stand trial; sanity commission found capacity to distinguish right from wrong.
Event: Sept. 11, 2008, Smith babysat two children and her own infant; infant died; injury pattern suggested blunt force/thermal injuries.
Police responded; initial statements given at the detective bureau after Miranda rights waiver; three taped statements obtained.
Evidence included DNA and serology linking blood to victim; a white towel with blood found in trash; dryer-related evidence.
Trial court admitted videotaped turkey-dryer demonstration; defense objected late, leading to various evidentiary issues; conviction and sentence affirmed on appeal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Voluntariness of the statements	Smith’s emotional distress rendered statements involuntary	State failed to prove voluntary, intelligent waiver	Waiver voluntary; statements voluntary under totality of circumstances
Miranda advisement and waiver sufficiency	Rights were not adequately explained repeatedly	Rights explained; waiver intelligent	Rights were adequately advised; waiver intelligent and voluntary
Admission of Turkey video demonstration	Experiment was prejudicial and inaccurate	Demonstrative evidence relevant to how injuries occurred	Video admissible under harmless error analysis; verdict not affected by error
Preservation of error on other crimes evidence	Objection should have been timely; error preserved	Objection not contemporaneous; waived	Issue preserved? No; barred by La.C.Cr.P. 841(A) as not timely objected

Miranda v. Arizona, 384 U.S. 436 (U.S. 1966) (mandatory rights advisement for custodial interrogation)
State v. Leger, 936 So.2d 108 (La. 2006) (appeals on evidentiary and competency issues)
State v. Hunt, 25 So.3d 746 (La. 2009) (routine post-conviction and evidentiary standards)