State of Louisiana v. Anthony Scott Tubbs

CourtLouisiana Court of Appeal
DecidedNovember 20, 2019
Docket52,417-KA
StatusPublished

This text of State of Louisiana v. Anthony Scott Tubbs (State of Louisiana v. Anthony Scott Tubbs) 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. Anthony Scott Tubbs, (La. Ct. App. 2019).

Opinion

Judgment rendered November 20, 2019. Application for rehearing may be filed within the delay allowed by Art. 992, La. C. Cr. P.

No. 52,417-KA

COURT OF APPEAL SECOND CIRCUIT STATE OF LOUISIANA

*****

STATE OF LOUISIANA Appellee

versus

ANTHONY SCOTT TUBBS Appellant

Appealed from the Twenty-Sixth Judicial District Court for the Parish of Bossier, Louisiana Trial Court No. 209,089

Honorable Parker Self, Judge

FLOWERS, LONG & HATCH, LLP Counsel for Appellant By: Christopher Hatch

J. SCHUYLER MARVIN Counsel for Appellee District Attorney

JOHN MICHAEL LAWRENCE Assistant District Attorney

Before PITMAN, GARRETT, and STEPHENS, JJ. GARRETT, J.

The defendant, Anthony Scott Tubbs, was convicted of insurance

fraud. He was ordered to serve five years at hard labor, with all but one year

suspended. He was placed on four years’ active, supervised probation and

ordered to pay a fine of $1,500, along with restitution. He appeals his

conviction and sentence. For the following reasons, we affirm.

FACTS

Tubbs operated ASAP Appliances (“ASAP”) in Bossier City,

Louisiana. The business sold and repaired used appliances. Richard Hayden

was an employee. On Saturday, May 12, 2012, the vehicles driven by

Hayden and Tubbs were parked in a lot behind the business. As Hayden was

leaving, he backed his Ford Expedition into a Dodge Ram 3500 truck which

was being used that day by Tubbs.1 Tubbs told the police officers who

responded to the accident that he was getting into his vehicle when the

accident occurred. Hayden later delivered a typed and signed statement to

the police taking full responsibility for the accident and stating that Tubbs

was entering his vehicle when the accident occurred.

At the scene, Tubbs said he was not injured, but asked for paramedics

to check him out because he had recently had a medical procedure. Tubbs

later claimed that he was seriously injured in the accident and filed a civil

lawsuit against Hayden, State Farm and USAA. State Farm later settled the

claim with Tubbs for $8,500. Tubbs also claimed to have been involved in

1 Hayden’s vehicle was owned by Donald Leaver, a relative of Hayden’s girlfriend at the time. The vehicle was insured by USAA Insurance Company (“USAA”). The vehicle being used by Tubbs was registered to Oris R. Corners and was insured by State Farm Insurance Company (“State Farm”). That vehicle was a large truck known as a “dually.” It had four wheels on the rear, two on each side. Tubbs also alleged that State Farm was his uninsured/underinsured motorist insurer. separate, unrelated accidents with other drivers on May 28, 2012, and

June 29, 2012, and received settlements from State Farm in those cases as

well. According to hospital records, the accident on May 28, 2012, occurred

when Tubbs was traveling in his truck at a low rate of speed and was

impacted on the passenger side by another vehicle. The accident on June 29,

2012, occurred when Tubbs claimed he was rear-ended in traffic by another

vehicle. Tubbs settled the second and third accidents with State Farm for

$10,494.18 and $10,592.04, respectively.

Tubbs’s insurance claims were eventually investigated by the

insurance fraud and auto theft unit of the Louisiana State Police. Hayden

changed his version of the events concerning the May 12 accident and said

that Tubbs was actually inside the business at the time the collision occurred.

In early 2015, Tubbs was charged with one count of insurance fraud in

connection with this accident. He was tried by a six-person jury. On

March 21, 2017, Tubbs was found guilty as charged. He filed motions for

new trial and for post verdict judgment of acquittal, which were denied by

the trial court on October 17, 2017.

On November 21, 2017, Tubbs was sentenced to serve five years at

hard labor, with all but one year suspended. He was given credit for time

served. He was placed on four years’ active, supervised probation and

ordered to pay a fine of $1,500, along with restitution to State Farm in the

amount of $8,500. Tubbs stated his intent to appeal.

After some procedural maneuvering, Tubbs filed a second motion for

new trial and sought an evidentiary hearing to supplement the record. The

trial court denied the second motion for new trial as untimely. Tubbs now

appeals, claiming there was insufficient evidence to support his conviction, 2 the trial court erred when it denied his first motion for new trial, and the

sentence imposed was excessive.2

SUFFICIENCY OF THE EVIDENCE

Tubbs argues that the evidence adduced at trial was insufficient to

support his conviction for insurance fraud. This argument is without merit.

Legal Principles

The standard of appellate review for a sufficiency of the evidence

claim is whether, after viewing the evidence in the light most favorable to

the prosecution, any rational trier of fact could have found the essential

elements of the crime proven beyond a reasonable doubt. Jackson v.

Virginia, 443 U.S. 307, 99 S. Ct. 2781, 61 L. Ed. 2d 560 (1979); State v.

Tate, 2001-1658 (La. 5/20/03), 851 So. 2d 921, cert. denied, 541 U.S. 905,

124 S. Ct. 1604, 158 L. Ed. 2d 248 (2004); State v. Hughes, 2018-0006 (La.

6/26/19), ___ So. 3d ___, 2019 WL 2750945; State v. Turner, 52,510 (La.

App. 2 Cir. 4/10/19), 267 So. 3d 1202, writ denied, 2019-00873 (La.

9/24/19), ___ So. 3d ___, 2019 WL 4884059. This standard, now

legislatively embodied in La. C. Cr. P. art. 821, does not provide the

appellate court with a vehicle to substitute its own appreciation of the

evidence for that of the factfinder. State v. Pigford, 2005-0477 (La.

2/22/06), 922 So. 2d 517; State v. Dotie, 43,819 (La. App. 2 Cir. 1/14/09), 1

So. 3d 833, writ denied, 2009-0310 (La. 11/6/09), 21 So. 3d 297; State v.

Turner, supra.

The Jackson standard is applicable in cases involving both direct and

circumstantial evidence. Direct evidence provides proof of the existence of

2 Tubbs has chosen not to challenge the trial court’s ruling that the second motion for new trial was untimely. Tubbs is represented by different counsel on appeal. 3 a fact, for example, a witness’s testimony that he saw or heard something.

State v. Turner, supra; State v. Wooten, 51,738 (La. App. 2 Cir. 2/13/18),

244 So. 3d 1216. An appellate court reviewing the sufficiency of evidence

in such cases must resolve any conflict in the direct evidence by viewing that

evidence in the light most favorable to the prosecution. When the direct

evidence is thus viewed, the facts established by the direct evidence and

inferred from the circumstances established by that evidence must be

sufficient for a rational trier of fact to conclude beyond a reasonable doubt

that the defendant was guilty of every essential element of the crime. State

v. Sutton, 436 So. 2d 471 (La. 1983); State v. Turner, supra.

Circumstantial evidence is defined as evidence of facts or

circumstances from which one might infer or conclude the existence of other

connected facts. Circumstantial evidence consists of proof of collateral facts

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Mesarosh v. United States
352 U.S. 1 (Supreme Court, 1956)
Jackson v. Virginia
443 U.S. 307 (Supreme Court, 1979)
Robertson v. Casual Corner Group, Inc
541 U.S. 905 (Supreme Court, 2004)
State v. Lyles
858 So. 2d 35 (Louisiana Court of Appeal, 2003)
State v. Brown
410 So. 2d 1043 (Supreme Court of Louisiana, 1982)
State v. Palmer
448 So. 2d 765 (Louisiana Court of Appeal, 1984)
State v. Guidry
647 So. 2d 502 (Louisiana Court of Appeal, 1994)
State v. Coleman
959 So. 2d 465 (Supreme Court of Louisiana, 2007)
State v. Smith
661 So. 2d 442 (Supreme Court of Louisiana, 1995)
State v. Dotie
1 So. 3d 833 (Louisiana Court of Appeal, 2009)
Jackson v. United Services Automobile Ass'n Casualty Insurance Co.
1 So. 3d 512 (Louisiana Court of Appeal, 2008)
State v. Dorthey
623 So. 2d 1276 (Supreme Court of Louisiana, 1993)
State v. Landry
15 So. 3d 138 (Louisiana Court of Appeal, 2009)
State v. Cook
674 So. 2d 957 (Supreme Court of Louisiana, 1996)
State v. Weaver
805 So. 2d 166 (Supreme Court of Louisiana, 2002)
State v. Kelly
576 So. 2d 111 (Louisiana Court of Appeal, 1991)
State v. Bonanno
384 So. 2d 355 (Supreme Court of Louisiana, 1980)
State v. Pigford
922 So. 2d 517 (Supreme Court of Louisiana, 2006)
State v. Rollins
749 So. 2d 890 (Louisiana Court of Appeal, 1999)
State v. Tate
851 So. 2d 921 (Supreme Court of Louisiana, 2003)

Cite This Page — Counsel Stack

Bluebook (online)
State of Louisiana v. Anthony Scott Tubbs, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-louisiana-v-anthony-scott-tubbs-lactapp-2019.