State v. Wiley, 68 So. 3d 583

Trevon Wiley was indicted for second degree murder and aggravated burglary; case severed for trial.
Trial ended with a jury verdict of guilty on both counts on August 19, 2009.
Sentences: life imprisonment for second degree murder; 30-year aggravated burglary with 20 years flat time; sentences run concurrently.
Key physical and testimonial evidence included DNA and fingerprint from a gum at the crime scene, and a recovered firearm.
Victim’s cellular phone records and SIM-card data linked to co-defendants and Wiley’s girlfriend, supporting involvement.
Wiley challenged sufficiency of the evidence and admission of certain witness-evidence; the court addressed patent error and remanded to remove flat-time provision.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was the evidence sufficient for second degree murder?	Wiley (State) contends evidence supports principal-to-murder via burglary.	Wiley contends circumstantial evidence does not prove murder beyond reasonable doubt.	Evidence sufficient to prove murder; Wiley as a principal established; conviction affirmed.
Was Barrette's cross-examination properly limited regarding arrests and false reports?	State contends cross-exam allowed to show bias and credibility.	Wiley argues Barrette’s arrests and false-reports history should be admitted to impeach credibility.	Trial court did not abuse discretion; Barrette could testify and arrests not disclosed to jury.
Were patent-errors in sentencing properly addressed on appeal?	State argues no prejudice given mandatory life sentence for murder and some harmless error for burglary.	Wiley asserts improper flat-time and lack of 24-hour delay require remand.	Restrictions on flat time removed on remand; delay issue deemed harmless for murder and burglary analysis; remand for correction.

State v. Hearold, 603 So.2d 731 (La.1992) (sufficiency review and standard of proof)
State v. Tolliver, 11 So.3d 584 (La.App. 3 Cir. 2009) (circumstantial evidence and sufficiency in murder cases)
State v. McFarland, 960 So.2d 1142 (La.App. 5 Cir. 2007) (principal-to-murder liability in burglary context)
State v. Hill, 742 So.2d 690 (La.App. 5 Cir. 1999) (sufficiency where defendant at least a principal)
State v. Frith, 985 So.2d 792 (La.App. 5 Cir. 2008) (evidence standards for circumstantial cases)
State v. Neal, 796 So.2d 649 (La.2002) (circumstantial evidence and inference standard)
State v. Vale, 666 So.2d 1070 (La.1996) (bias evidence and witness credibility balancing)
State v. Rankin, 465 So.2d 679 (La.1985) (cross-examination of witnesses with pending charges)
State v. Brady, 381 So.2d 819 (La.1980) (use of witness's pending charges for bias)
State v. Bowie, 813 So.2d 377 (La.2002) (bias or interest as cross-examination topic)