State v. Strickland, 91 So. 3d 411

Kevin Strickland was convicted by a six-person jury of second degree battery and resisting an officer with force or violence.
The charges stemmed from an May 10, 2010 incident where Jones suffered severe injuries after an altercation with Strickland involving biting and punches.
Strickland testified that he acted in self-defense in a lengthy disputed confrontation initiated by Jones.
The trial court denied post-verdict motions; Strickland was sentenced to six months for resisting an officer and five years for second degree battery, to run concurrently.
On appeal, Strickland challenged the sufficiency of the evidence, self-defense, a confrontation clause issue, and various sentencing/notice problems highlighted as errors patent.
The court affirmed the conviction, remanded for a fine discrepancy, and addressed sentencing timing and other ancillary rulings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was the evidence sufficient for second degree battery?	Strickland asserts insufficient proof of intent to inflict serious bodily injury.	State failed to prove lack of self-defense and failed to prove specific intent beyond a reasonable doubt.	Sufficiency established; rational juror could find intent to inflict serious bodily injury.
Did the evidence support rejection of Strickland's self-defense claim?	State showed Strickland aggressed first and did not withdraw in good faith.	Strickland acted in self-defense; deathless or minimal injuries do not negate self-defense.	Court found no error in rejecting self-defense; aggressor status supported denial of self-defense.
Did the trial court violate the confrontation clause regarding impeachment of Jones?	Defense sought to impeach Jones with a Texas conviction; limited by 609.1.	Defense was improperly limited; confrontation rights violated by exclusion.	Issue waived; defense failed to object contemporaneously and did not proffer excluded testimony.
Were there errors patent requiring remand or correction?	Discrepancy between commitment and transcript for fines; improper sentencing delay under Article 873.	Delay remedied by tacit waiver; no prejudice shown; other errors too minor to remand.	Remanded for fine discrepancy clarification; otherwise no reversible error; no remand for sentencing.

Jackson v. Virginia, 443 U.S. 307 (U.S. (1979)) (sufficiency of evidence standard)
State v. Fuller, 414 So.2d 306 (La.1982) (elements of second degree battery)
State v. Hall, 871 So.2d 558 (La.App.5 Cir. 2004) (specific intent and self-defense considerations)
State v. Patterson, 63 So.3d 140 (La.App.5 Cir. 2011) (inference of specific intent from circumstances)
State v. Durand, 963 So.2d 1028 (La.App.5 Cir. 2007) (circumstantial evidence and reasonable hypotheses)
State v. Freeman, 427 So.2d 1161 (La.1983) (dual inquiry for self-defense; objective and subjective tests)
State v. Nailor, 78 So.3d 816 (La.App.5 Cir. 2011) (credibility and rulings on self-defense)
State v. Steele, 829 So.2d 541 (La.App.5 Cir. 2002) (self-defense and aggressor status standards)
State v. Baker, 816 So.2d 363 (La.App.5 Cir. 2002) (assessment of conflicting testimony)
State v. Seals, 684 So.2d 368 (La.1996) (errors patent review authority)
State v. Upchurch, 783 So.2d 398 (La.App.5 Cir. 2001) (sentencing confinement and labor distinctions)
State v. Lynch, 441 So.2d 732 (La.1983) (transcript vs minute entry conflict; transcript prevails)
State v. Nicholas, 67 So.3d 610 (La.App.5 Cir. 2011) (remand considerations for timing)