State Of Louisiana v. Courtney Garnett

CourtLouisiana Court of Appeal
DecidedFebruary 21, 2024
Docket2023KA0699
StatusUnknown

This text of State Of Louisiana v. Courtney Garnett (State Of Louisiana v. Courtney Garnett) 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. Courtney Garnett, (La. Ct. App. 2024).

Opinion

STATE OF LOUISIANA

COURT OF APPEAL

FIRST CIRCUIT

2023 KA 0699

VERSUS

COURTNEY GARNETT

Judgment Rendered: FEB 2 12024

On Appeal from the Seventeenth Judicial District Court In and for the Parish of Lafourche State of Louisiana Docket No. 577581

Honorable Marla M. Abel, Judge Presiding

Kristine Russell Counsel for Appellee District Attorney State of Louisiana and-

Jason Chatagnier Gregory Stahlnecker Joseph S. Soignet Assistant District Attorneys Thibodaux, Louisiana

Kevin V. Boshea Counsel for Defendant/ Appellant Metairie, Louisiana Courtney Garnett

BEFORE: MCCLENDON, HESTER, AND MILLER, 33. McCLENDON, I

Defendant, Courtney Garnett, was charged by bill of information with attempted

second degree murder ( count one), a violation of LSA- R. S. 14: 27 and LSA- R. S. 14: 30. 1,

and aggravated battery ( count two), a violation of LSA- R. S. 14: 34. He initially entered a

plea of not guilty. Upon motion of defendant, the trial court appointed a sanity

commission to determine defendant's competency to stand trial. After a sanity hearing,

the trial court found that defendant did not have the mental capacity to proceed.

Defendant was committed to the Department of Health and Hospitals, reevaluated, and

found competent to stand trial, but changed his plea to not guilty and not guilty by reason

of insanity.

After a trial by jury, defendant was found guilty as charged on count one and guilty

of the responsive offense of second degree battery on count two, a violation of LSA- R.S.

14: 34. 1. See LSA- C. Cr. P. art. 814( A)( 18). The trial court denied a combined motion for

new trial and motion for post -verdict judgment of acquittal filed by defendant and

imposed a sentence of twenty- five years imprisonment at hard labor without the benefit

of probation, parole, or suspension of sentence on count one, and a sentence of five

years imprisonment at hard labor on count two, to be served concurrently. The trial court

denied defendant' s motion to reconsider sentence. Defendant now appeals, assigning

error to the sufficiency of the evidence based on his defense of insanity, the

constitutionality of the sentences, and the denial of his post -trial motions. For the

following reasons, we affirm the convictions and sentences.

STATEMENT OF FACTS

On June 26, 2018, at approximately 4: 30 a. m., defendant physically attacked

Jarius LeBlanc and Cade Legendre, two workers at Lafourche Parish Water District, in

Thibodaux, Louisiana. Defendant initially approached Mr. LeBlanc, pulled him to the

ground, got on top of him, and began stabbing him with a knife in the back, face, and

neck. Mr. Legendre heard Mr. LeBlanc screaming for help and ran to assist him, at which

point defendant charged toward Mr. Legendre, and started punching and kicking him.

Mr. LeBlanc then went to his truck that was parked in the nearby lot, and grabbed his

loaded pistol from between the driver's seat and middle seat. Defendant saw Mr. LeBlanc

2 at his truck, approached him from behind, pulled the gun away from him, and fired the

gun at him, but missed. Defendant pulled the trigger again, but the gun did not fire.

Defendant then walked away toward an open cane field. Mr. Legendre called 911.

Defendant was located in a ditch by the field, taken into police custody, and confessed in

a recorded interview.

SUFFICIENCY OF THE EVIDENCE'

In assignment of error number one, defendant argues the verdicts are " irrational",

maintaining that he proved by a preponderance of the evidence that he was insane at

the time of the offenses. Thus, in assignments of error numbers three and four,

respectively, he argues that the trial court erred in denying his motion for new trial and

in failing to reject the jury's verdict and render a post -verdict judgment of not guilty and

not guilty by reason of insanity.

A conviction based on insufficient evidence cannot stand, as it violates due

process. See U. S. Const. amend. XIV, LSA -Const. art. I, § 2. The standard of review for

sufficiency of the evidence to support a conviction is whether, viewing the evidence in

the light most favorable to the prosecution, a rational trier of fact could conclude that the

State proved the essential elements of the crime beyond a reasonable doubt. See LSA-

C. Cr. P. art. 821( 6); Jackson v. Virginia, 443 U. S. 307, 319, 99 S. Ct. 2781, 2789, 61

L. Ed. 2d 560 ( 1979); State v. Ordodi, 2006- 0207 ( La. 11/ 29/ 06), 946 So -2d 654, 660;

State v. Welch, 2019- 0826 ( La. App. 1 Cir. 2/ 21/ 20), 297 So. 3d 23, 27, writ denied,

2020- 00554 ( La. 9/ 29/ 20), 301 So. 3d 1193.

The Jackson standard of review, incorporated in Article 821, is an objective

standard for testing the overall evidence, both direct and circumstantial, for reasonable

doubt. Welch, 297 So. 3d at 27. When a conviction is based on both direct and

circumstantial evidence, the reviewing court must resolve any conflict in the direct

1 In his motion for new trial, defendant argues that the verdicts are not supported by trial testimony and that the ends of justice would be served by the granting of a new trial. At the hearing on the post -trial motions, he argued the victims' injuries were not serious or life threatening. As he has not re -raised this argument on appeal, it is considered abandoned. See Uniform Rules of Louisiana Courts of Appeal, Rule 2- 12. 4. we further note that a motion for post -verdict judgment of acquittal is the proper procedural vehicle for raising the sufficiency of the evidence. See LSA- C. Cr. P. art. 821. A motion for a new trial challenging the sufficiency of the evidence is a question of fact outside of the higher courts' scope of review. But, a ruling on a motion for new trial on the ground of serving the ends of justice presents a question of law, which should not be disturbed on review unless the trial court abused its great discretion. State v. Guillory, 2010- 1231 ( La. 10/ 8/ 10), 45 So. 3d 612, 615.

3 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 the

facts reasonably inferred from the circumstantial evidence must be sufficient for a rational juror to conclude beyond a reasonable doubt that the defendant was guilty of every

essential element of the crime. State v. Coleman, 2021- 0870 ( La. App. 1 Or. 4/ 8/ 22),

342 So. 3d 7, 12, writ denied, 2022- 00759 ( La. 11/ 21/ 23), 373 So. 3d 460.

When analyzing circumstantial evidence, LSA- R. S. 15: 438 provides that the

factfinder must be satisfied that the overall evidence excludes every reasonable

hypothesis of innocence. When a case involves circumstantial evidence and the jury

reasonably rejects the hypothesis of innocence presented by the defense, that hypothesis

falls, and the defendant is guilty unless there is another hypothesis which raises a

reasonable doubt. State v. Southall, 2022- 0746 ( La. App. 1 Cir. 6/ 2/ 23), 369 So. 3d

925, 930, writ denied, 2023- 00875 La. 2/ 6/ 24), So. 3d , 2024 WL 445884.

Second degree murder is the killing of a human being when the offender has a

specific intent to Will or to inflict great bodily harm. LSA- R. S. 14: 30. 1( A)( 1). Any person

who, having a specific intent to commit a crime, does or omits an act for the purpose of

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State Of Louisiana v. Courtney Garnett, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-louisiana-v-courtney-garnett-lactapp-2024.