State of Louisiana v. Bobby Joe Statum

CourtLouisiana Court of Appeal
DecidedMarch 7, 2007
DocketKA-0006-1340
StatusUnknown

This text of State of Louisiana v. Bobby Joe Statum (State of Louisiana v. Bobby Joe Statum) 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. Bobby Joe Statum, (La. Ct. App. 2007).

Opinion

DO NOT PUBLISH

STATE OF LOUISIANA COURT OF APPEAL, THIRD CIRCUIT

06-1340

STATE OF LOUISIANA

VERSUS

BOBBY JOE STATUM ********** APPEAL FROM THE THIRTY-SIXTH JUDICIAL DISTRICT COURT PARISH OF BEAUREGARD, NO.CR-696-2004 HONORABLE STUART S. KAY, DISTRICT JUDGE

**********

J. DAVID PAINTER

********** Court composed of John D. Saunders, Glenn B. Gremillion, and J. David Painter, Judges.

AFFIRMED. David W. Burton District Attorney, 36th Judicial District P. O. Box 99 DeRidder, LA 70634 Counsel for Appellee: State of Louisiana

Michael M. Evans, II Attorney at Law 416 N. Pine Street DeRidder, LA 70634 Counsel for Defendant-Appellant: Bobby Joe Statum PAINTER, Judge.

Defendant, Bobby Joe Statum, appeals his conviction for manslaughter in

connection with the death of James Mills. He asserts that the evidence was

insufficient to convict him of manslaughter and that the trial court abused its

discretion in failing to recess the trial to allow his forensic entomologist to testify

regarding samples taken from the crime scene.

FACTS

On November 18, 2003, Defendant, several other men, and Mills were at Willie

Stains’ fishing camp. The last time Mills was seen alive, he was walking away from

the camp with Defendant. Mills was discovered dead outside of his trailer by a friend

on November 20, 2003.

The investigation of Mills’ death revealed that he sustained a skull crushing

blow to the head as well as multiple lacerations and cuts, one of which severed the

jugular vein. According to the testimony, it appears that Mills received the wounds

while he was inside his camp and was later dragged outside where his body was

found. The coroner testified that the estimated time of death was late on November

18, 2003, or early morning on November 19, 2003. Dr. Erin Watson, an

entomologist, opined in her report that the time of death was between sunset on

November 19, 2003, and sunrise on November 20, 2003.

Inside the trailer, the assailant left tread prints from his tennis shoes in Mills’

blood. During the investigation, authorities learned that on or about November 30,

2003, Defendant’s mother, Betty Statum, found a pair of Defendant’s tennis shoes

under her bed and disposed of them in a river. A shoe similar to the ones discarded

by Ms. Statum was found on January 9, 2004, about one and a half miles down the

1 river from where she tossed them. According to Bob Fry, a forensic analyst, the shoe

was the same brand of shoe, approximately the same size, and had the same tread

pattern as the shoe that made the impressions at the crime scene.

A bloody cigarette butt was found outside near Mills’ body. The DNA from

the bloody paper on the butt and the filter were tested and indicated that Mills’ DNA

from the blood was on the paper, and Defendant’s DNA was in the filter.

Lastly, a fellow inmate testified that Defendant admitted to killing Mills.

According to the inmate, Defendant stated that he used a knife and a baseball bat in

the commission of the crime.

PROCEDURAL HISTORY

On March 29, 2005, Defendant was charged by bill of indictment with second

degree murder, a violation of La.R.S. 14:30.1. Following a jury trial held on March

20-24, 2006, the jury found Defendant guilty of manslaughter.

Defendant was subsequently charged as a habitual offender on April 24, 2006.

Following a hearing held on July 21, 2006, he was adjudicated a fourth felony

habitual offender. He was sentenced that same day to serve the remainder of his life

at hard labor without benefit of probation, parole, or suspension of sentence. The trial

court also noted that Defendant was not entitled to diminution of sentence for good

behavior under La.R.S. 15:571.3(C)(2) & (3).

DISCUSSION

Sufficiency of the Evidence

Four of Defendant’s five assignments of error concern the sufficiency of the

evidence. Defendant argues that the evidence adduced at trial was not sufficient to

support a conviction for manslaughter. The remaining assignment concerns the

2 court’s refusal to continue the trial so that his expert forensic entomologist could

testify. As noted in State v. Hearold, 603 So.2d 731, 734 (La.1992):

When issues are raised on appeal both as to the sufficiency of the evidence and as to one or more trial errors, the reviewing court should first determine the sufficiency of the evidence. The reason for reviewing sufficiency first is that the accused may be entitled to an acquittal under Hudson v. Louisiana, 450 U.S. 40, 101 S.Ct. 970, 67 L.Ed.2d 30 (1981), if a rational trier of fact, viewing the evidence in accordance with Jackson v. Virginia, 443 U.S. 307, 99 S.Ct. 2781, 61 L.Ed.2d 560 (1979) in the light most favorable to the prosecution, could not reasonably conclude that all of the essential elements of the offense have been proved beyond a reasonable doubt.

Accordingly, we first address whether the entirety of the evidence is sufficient

to support Defendant’s conviction.

The analysis for a claim of insufficient evidence is well-settled:

When the issue of sufficiency of evidence is raised on appeal, the critical inquiry of the reviewing court 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, rehearing denied, 444 U.S. 890, 100 S.Ct. 195, 62 L.Ed.2d 126 (1979); State ex rel. Graffagnino v. King, 436 So.2d 559 (La.1983); State v. Duncan, 420 So.2d 1105 (La.1982); State v. Moody, 393 So.2d 1212 (La.1981). It is the role of the fact finder to weigh the respective credibility of the witnesses, and therefore, the appellate court should not second guess the credibility determinations of the triers of fact beyond the sufficiency evaluations under the Jackson standard of review. See State ex rel. Graffagnino, 436 So.2d 559 (citing State v. Richardson, 425 So.2d 1228 (La.1983)). In order for this Court to affirm a conviction, however, the record must reflect that the state has satisfied its burden of proving the elements of the crime beyond a reasonable doubt.

State v. Kennerson, 96-1518, p. 5 (La.App. 3 Cir. 5/7/97), 695 So.2d 1367, 1371.

The elements of the crime at issue are set forth in La.R.S. 14:31, which states,

in pertinent part:

3 A. Manslaughter is:

(1) A homicide which would be murder under either Article 30 (first degree murder) or Article 30.1 (second degree murder), but the offense is committed in sudden passion or heat of blood immediately caused by provocation sufficient to deprive an average person of his self-control and cool reflection. Provocation shall not reduce a homicide to manslaughter if the jury finds that the offender's blood had actually cooled, or that an average person’s blood would have cooled, at the time the offense was committed; or

(2) A homicide committed, without any intent to cause death or great bodily harm.

(a) When the offender is engaged in the perpetration or attempted perpetration of any felony not enumerated in Article 30 or 30.1, or of any intentional misdemeanor directly affecting the person; or

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Related

Jackson v. Virginia
443 U.S. 307 (Supreme Court, 1979)
Hudson v. Louisiana
450 U.S. 40 (Supreme Court, 1981)
State v. Rogers
494 So. 2d 1251 (Louisiana Court of Appeal, 1986)
State v. Smith
632 So. 2d 887 (Louisiana Court of Appeal, 1994)
State v. Kennerson
695 So. 2d 1367 (Louisiana Court of Appeal, 1997)
State v. Touchet
642 So. 2d 1213 (Supreme Court of Louisiana, 1994)
State v. Richardson
425 So. 2d 1228 (Supreme Court of Louisiana, 1983)
State v. Hodges
749 So. 2d 732 (Louisiana Court of Appeal, 1999)
State Ex Rel. Graffagnino v. King
436 So. 2d 559 (Supreme Court of Louisiana, 1983)
State Ex Rel. Elaire v. Blackburn
424 So. 2d 246 (Supreme Court of Louisiana, 1982)
State v. Jenkins
846 So. 2d 778 (Louisiana Court of Appeal, 2003)
State v. Duncan
420 So. 2d 1105 (Supreme Court of Louisiana, 1982)
State v. Moody
393 So. 2d 1212 (Supreme Court of Louisiana, 1981)
State v. Hearold
603 So. 2d 731 (Supreme Court of Louisiana, 1992)
State v. Plaisance
811 So. 2d 1172 (Louisiana Court of Appeal, 2002)

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