State of Louisiana v. Adam Batiste, III

CourtLouisiana Court of Appeal
DecidedApril 6, 2016
DocketKA-0015-1008
StatusUnknown

This text of State of Louisiana v. Adam Batiste, III (State of Louisiana v. Adam Batiste, III) is published on Counsel Stack Legal Research, covering Louisiana Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State of Louisiana v. Adam Batiste, III, (La. Ct. App. 2016).

Opinion

STATE OF LOUISIANA COURT OF APPEAL, THIRD CIRCUIT

15-1008

STATE OF LOUISIANA

VERSUS

ADAM BATISTE, III

**********

APPEAL FROM THE FIFTEENTH JUDICIAL DISTRICT COURT PARISH OF LAFAYETTE, NO. CR-141203 HONORABLE EDWARD D. RUBIN, DISTRICT JUDGE

ELIZABETH A. PICKETT JUDGE

Court composed of Marc T. Amy, Elizabeth A. Pickett, and James T. Genovese, Judges.

AFFIRMED.

Keith A. Stutes District Attorney, Fifteenth Judicial District Cynthia K. Simon Assistant District Attorney P. O. Box 3306 Lafayette, LA 70502-3306 (337) 232-5170 COUNSEL FOR APPELLEE: State of Louisiana Chad M. Ikerd Louisiana Appellate Project P.O.Box 2125 Lafayette, LA 70502 (225) 806-2930 COUNSEL FOR DEFENDANT- APPELLANT: Adam Batiste, III

Adam Batiste, III Hickory #1 Louisiana State Penitentiary Angola, LA 70712 Pro Se PICKETT, Judge.

FACTS

On January 16, 2013, the defendant Adam Batiste, III called 911 and

requested help for his girlfriend, Gabriella Spencer, stating that she had fallen in

the shower, was not responsive, and was barely breathing. When the fire

department arrived, they saw that Ms. Spencer appeared to have been severely

beaten and summoned the police. Ms. Spencer was taken to the hospital where it

was determined she also suffered from a subdural hematoma which caused her

death shortly thereafter. The defendant was subsequently arrested for the second

degree murder of Ms. Spencer.

The defendant was indicted on March 22, 2013, for the second degree

murder of Gabriella Spencer, a violation of La.R.S. 14:30.1. A jury trial

commenced on April 29, 2015. On May 1, 2015, the jury returned a verdict of

guilty as charged.

The defendant was sentenced on May 6, 2015, to life imprisonment without

the benefit of parole, probation, or suspension of sentence. The defendant did not

file a motion to reconsider the sentence.

The defendant has perfected a timely appeal. He asserts that “[t]he State

failed to offer sufficient evidence that Adam Batiste committed second degree

murder and did not negate the reasonable probability that the fatal injury was

accidentally self-inflicted.” The defendant has also filed a pro-se brief, which

alleges insufficient evidence and ineffective assistance of trial counsel.

ERRORS PATENT

In accordance with La.Code Crim.P. art. 920, all appeals are reviewed by

this court for errors patent on the face of the record. After reviewing the record,

we find there are no errors patent. ATTORNEY ASSIGNMENT OF ERROR NUMBER ONE, AND PRO SE

ASSIGNMENT OF ERROR NUMBER ONE:

The defendant argues the state failed to negate the reasonable hypothesis that

Ms. Spencer’s injuries were accidently self-inflicted when she fell in the shower.

Alternatively, he suggests her injuries were caused by some unknown persons who

beat her up on December 28, 2012, and possibly caused the head injury at the same

time. Since there was no eyewitness to what caused any of Ms. Spencer’s injuries,

and the defendant did not confess to causing her injuries, the verdict was based

solely on circumstantial evidence. The circumstantial evidence rule states that

“assuming every fact to be proved that the evidence tends to prove, in order to

convict, it must exclude every reasonable hypothesis of innocence.” La.R.S.

15:438. The defendant asserts that with only the circumstantial evidence, the state

failed to prove he caused the victim’s death; accordingly, the evidence was

insufficient to sustain the verdict.

This court has stated that questions of the sufficiency of the evidence are

considered using the following standard of review:

[A] reviewing court must consider the evidence presented in the light most favorable to the prosecution and consider whether a rational trier of fact could have concluded that the essential elements of the offense were proven beyond a reasonable doubt. See Jackson v. Virginia, 443 U.S. 307, 99 S.Ct. 2781, 61 L.Ed.2d 560 (1979). The reviewing court defers to rational credibility and evidentiary determinations of the trier of fact. State v. Marcantel, 00-1629 (La.4/3/02), 815 So.2d 50.

State v. Chesson, 03-606, p. 5 (La.App. 3 Cir. 10/1/03), 856 So.2d 166, 172, writ

denied, 03-2913 (La. 2/13/04), 867 So.2d 686.

Additionally, in State v. Williams, 13-497, pp. 4-5 (La.App. 3 Cir. 11/6/13),

124 So.3d 1236, 1240, writ denied, 13-2774 (La. 5/16/14), 139 So.3d 1024, this

court noted:

2 “Evidence may be either direct or circumstantial.” State v. Jacobs, 07-887, p. 12 (La.App. 5 Cir. 5/24/11), 67 So.3d 535, 551, writ denied, 11-1753 (La.2/10/12), 80 So.3d 468, cert. denied, ___ U.S. ___, 133 S.Ct. 139, 184 L.Ed.2d 67 (2012). We note that, whether the conviction is based on direct evidence or solely on circumstantial evidence, the review is the same under the Jackson v. Virginia standard. State v. Williams, 33,881 (La.App. 2 Cir. 9/27/00), 768 So.2d 728 (citing State v. Sutton, 436 So.2d 471 (La.1983)), writ denied, 00-99 (La.10/5/01), 798 So.2d 963. Circumstantial evidence is that where the main fact can be inferred, using reason and common experience, from proof of collateral facts and circumstances. Id. Where the conviction is based on circumstantial evidence, in order to convict, “assuming every fact to be proved that the evidence tends to prove, in order to convict, it must exclude every reasonable hypothesis of innocence.” La.R.S. 15:438.

In State v. Chism, 436 So.2d 464, 469 (La.1983) (citations omitted), the supreme court discussed the use of circumstantial evidence, stating:

Circumstantial evidence involves, in addition to the assertion of witnesses as to what they have observed, a process of reasoning, or inference by which a conclusion is drawn. Like all other evidence, it may be strong or weak; it may be so unconvincing as to be quite worthless, or it may be irresistible and overwhelming. There is still no man who would not accept dog tracks in the mud against the sworn testimony of a hundred eye- witnesses that no dog passed by. The gist of circumstantial evidence, and the key to it, is the inference, or process of reasoning by which the conclusion is reached. This must be based on the evidence given, together with a sufficient background of human experience to justify the conclusion.

Consequently, before a trier of fact can decide the ultimate question of whether a reasonable hypothesis of innocence exists in a criminal case based crucially on circumstantial evidence, a number of preliminary findings must be made. In addition to assessing the circumstantial evidence in light of the direct evidence, and vice versa, the trier of fact must decide what reasonable inferences may be drawn from the circumstantial evidence, the manner in which competing inferences should be resolved, reconciled or compromised; and the weight and effect to be given to each permissible inference. From facts found from direct evidence and inferred from circumstantial evidence, the trier of fact should proceed, keeping in mind the relative strength and weakness of each inference and finding, to decide the ultimate question of whether this body of 3 preliminary facts excludes every reasonable hypothesis of innocence.

In the current case, the defendant was convicted of second degree murder,

which is the killing of a human being “[w]hen the offender has a specific intent to

kill or to inflict great bodily harm[.]” La.R.S. 14:30.1(A)(1). At trial, the

following testimonies and exhibits were presented:

On January 16, 2013, Robert Davis, a firefighter with the Lafayette Fire

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Related

Jackson v. Virginia
443 U.S. 307 (Supreme Court, 1979)
Strickland v. Washington
466 U.S. 668 (Supreme Court, 1984)
State v. Bienemy
483 So. 2d 1105 (Louisiana Court of Appeal, 1986)
State v. Shapiro
431 So. 2d 372 (Supreme Court of Louisiana, 1983)
State v. Williams
383 So. 2d 369 (Supreme Court of Louisiana, 1980)
State v. Sias
861 So. 2d 829 (Louisiana Court of Appeal, 2003)
State v. Captville
448 So. 2d 676 (Supreme Court of Louisiana, 1984)
State v. Williams
768 So. 2d 728 (Louisiana Court of Appeal, 2000)
State v. Wry
591 So. 2d 774 (Louisiana Court of Appeal, 1991)
State v. Egan
26 So. 3d 938 (Louisiana Court of Appeal, 2009)
State v. Grant
954 So. 2d 823 (Louisiana Court of Appeal, 2007)
State v. TRUEHILL
38 So. 3d 1246 (Louisiana Court of Appeal, 2010)
State v. Ellis
966 So. 2d 139 (Louisiana Court of Appeal, 2007)
State v. Marcantel
815 So. 2d 50 (Supreme Court of Louisiana, 2002)
State v. Collins
896 So. 2d 1265 (Louisiana Court of Appeal, 2005)
State v. Chism
436 So. 2d 464 (Supreme Court of Louisiana, 1983)
State v. Sutton
436 So. 2d 471 (Supreme Court of Louisiana, 1983)
State v. Chesson
856 So. 2d 166 (Louisiana Court of Appeal, 2003)
State v. Schexnaider
852 So. 2d 450 (Louisiana Court of Appeal, 2003)
State v. Duplichan
945 So. 2d 170 (Louisiana Court of Appeal, 2006)

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