State v. Watts, 168 So. 3d 441

Background

Defendant James Thomas Watts was convicted by a jury of vehicular homicide after a 2011 collision that killed 16-year-old Phillip Abington; sentence: 12 years at hard labor (6 years suspended), fines and probation/special conditions.
Accident occurred on a clear day at intersection of Greenwell Springs Rd and Will Ave; victim stopped at stop sign, slowly entered traffic and was struck while attempting to turn; victim’s car was thrown 122 feet.
The defendant’s truck CDR recorded speeds rising from 87 to 95 mph in the 5–2 seconds before impact on a 45 mph road; brakes engaged one second before collision.
Blood drawn ~2 hours after the crash showed BAC 0.09%; troopers detected alcohol odor and bloodshot eyes at scene/hospital.
At trial, State introduced CDR data, blood test results, witness testimony, and lab procedure testimony about chain of custody and testing; defendant challenged sufficiency, blood-kit validity, consent/probable cause for blood draw, and CDR expert qualification.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence for vehicular homicide (causation and intoxication)	Evidence (CDR speeds, BAC ≥ .08, witness observations, damage, positioning) shows intoxication combined with reckless operation causing death	Victim’s conduct or other factors could have caused the crash; BAC two hours after may not prove impairment at impact	Conviction affirmed: evidence, viewed favorably to State, proved causal link and intoxication beyond reasonable doubt; jury credibility determinations upheld
Admissibility of blood test — blood collection kit approval	State: kit was issued/approved by LA State Police and lab procedures showed reliable chain of custody and equivalent protection	Kit was not an expressly listed B‑D or NIK kit under LA Admin. Code §555; thus test might be inadmissible	Admissible: kit was departmentally approved and State proved equivalency and proper handling; test results admitted
Lawfulness of blood draw / consent / probable cause	State: officer smelled alcohol, observed signs, defendant admitted driving, fatality occurred — statutory provisions deem consent or authorize test	Defendant: officer lacked probable cause to compel/obtain blood; thus consent was not lawful	Blood draw lawful: officer had reasonable grounds and fatality triggered statutory authority; defendant was deemed to have consented under statute
Qualification of CDR specialist (Trooper Biddy)	State: Biddy had reconstruction training and CDR experience sufficient to qualify as expert	Defendant: Biddy lacked adequate training and prior expert testimony experience	Trial court did not abuse discretion: Biddy’s training and role supported expert qualification; admissibility affirmed

Key Cases Cited

Jackson v. Virginia, 443 U.S. 307 (1979) (standard for sufficiency of evidence review)
State v. Taylor, 463 So.2d 1274 (La. 1985) (vehicular homicide requires causal link between intoxication and death)
State v. Green, 418 So.2d 609 (La. 1982) (equivalency allows admission where non‑listed collection device still protects specimen)
State v. Archer, 619 So.2d 1071 (La. App. 1 Cir.) (vehicular homicide reversal where alternate causal hypotheses prevailed)
State v. Bailey, 905 So.2d 303 (La. App. 3 Cir.) (reversal where other facts made intoxication causation insufficient)
State v. Weber, 139 So.3d 519 (La. 2014) (statutory standard for testing when fatality occurs; officer need only reasonable grounds)
State v. Captville, 448 So.2d 676 (La. 1984) (circumstantial evidence: jury may reject defense hypothesis; if rejected, defendant must produce another hypothesis creating reasonable doubt)
State v. Kalathakis, 563 So.2d 228 (La. 1990) (causation is a fact question reviewed under totality of circumstances)