State of Louisiana v. Elizabeth Marie Alfred A/K/A Elizabeth Alfred

CourtLouisiana Court of Appeal
DecidedMarch 1, 2023
DocketKA-0022-0477
StatusUnknown

This text of State of Louisiana v. Elizabeth Marie Alfred A/K/A Elizabeth Alfred (State of Louisiana v. Elizabeth Marie Alfred A/K/A Elizabeth Alfred) 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. Elizabeth Marie Alfred A/K/A Elizabeth Alfred, (La. Ct. App. 2023).

Opinion

STATE OF LOUISIANA COURT OF APPEAL, THIRD CIRCUIT

22-477

STATE OF LOUISIANA

VERSUS

ELIZABETH MARIE ALFRED

************ APPEAL FROM THE FIFTEENTH JUDICIAL DISTRICT COURT PARISH OF LAFAYETTE, DOCKET NO. CR-177317 HONORABLE MARILYN CARR CASTLE, DISTRICT JUDGE ************ LEDRICKA J. THIERRY JUDGE ************

Court composed of Elizabeth A. Pickett, Jonathan W. Perry, and Ledricka J. Thierry, Judges.

AFFIRMED.

Don Landry, District Attorney Kenneth P. Hebert, Assistant District Attorney 15th Judicial District P.O. Box 3306 Lafayette, LA 70501 (337) 232-5170 COUNSEL FOR APPELLEE: State of Louisiana

Chad M. Ikerd Louisiana Appellate Project P.O. Box 2125 Lafayette, LA 70502 (337) 366-8994 COUNSEL FOR DEFENDANT/APPELLANT: Elizabeth Marie Alfred THIERRY, Judge.

FACTS AND PROCEDURAL HISTORY

At approximately 10:47 p.m. on January 24, 2020, police officers were

dispatched to an apartment located at 804 Martin Luther King, Jr. Drive in Lafayette,

Louisiana, to respond to an aggravated battery. When the police arrived, they

discovered the victim, Phillip Joe Nelson, unresponsive due to an apparent stab

wound to the chest. Mr. Nelson was pronounced dead at the scene. The police

conducted an initial crime scene investigation which implicated Mr. Nelson’s “on-

again, off-again” girlfriend, Defendant, Elizabeth Marie Alford, as the assailant.

Defendant was questioned by the police and arrested for second degree murder on

January 25, 2020. After the grand jury did not return an indictment for second degree

murder, Defendant was formally charged with manslaughter.

On June 2, 2020, Defendant, Elizabeth Marie Alfred, was charged by bill of

information with manslaughter, in violation of La.R.S. 14:31. On June 11, 2020,

Defendant waived a formal reading of the bill and entered a plea of not guilty. A

jury unanimously found Defendant guilty of the responsive verdict of negligent

homicide, in violation of La.R.S. 14:32, on July 15, 2021.

On February 3, 2022, after a presentence investigation was conducted, the trial

court held a sentencing hearing, after which Defendant was sentenced to five years

at hard labor, with all but eighteen months suspended, and placed on three years of

active supervised probation. The trial court also ordered Defendant to pay court

costs in the amount of $435.50. Defendant’s motion to reconsider sentence was

denied without a hearing.

Defendant filed a motion for appeal which was granted by the trial court. She

is now before this court alleging one assignment of error: there was insufficient 2 evidence to sustain her negligent homicide conviction as the State failed to disprove

the homicide was committed in self-defense. For the reasons which follow, we

affirm Defendant’s conviction and sentence.

ANALYSIS

In her sole assignment of error, Defendant alleges the evidence was

insufficient to support her conviction for negligent homicide. Defendant does not

contest that she killed Mr. Nelson by stabbing him with a knife, but instead argues

the State failed to disprove beyond a reasonable doubt that the homicide was

committed in self-defense.

The standard of review in a sufficiency of the evidence claim is “whether,

viewing the evidence in the light most favorable to the prosecution, any rational trier

of fact could have found proof beyond a reasonable doubt of each of the essential

elements of the crime charged.” State v. Leger, 05-11, p. 91 (La. 7/10/06), 936 So.2d

108, 170, cert. denied, 549 U.S. 1221, 127 S.Ct. 1279 (2007), citing Jackson v.

Virginia, 443 U.S. 307, 99 S.Ct. 2781 (1979), State v. Captville, 448 So.2d 676, 678

(La.1984). The Jackson standard of review does not allow the appellate court “to

substitute its own appreciation of the evidence for that of the fact-finder.” State v.

Pigford, 05-477, p. 6 (La. 2/22/06), 922 So.2d 517, 521 (citations omitted). It is not

the appellate court’s function to assess the credibility of witnesses or to reweigh the

evidence. State v. Smith, 94-3116, p. 2 (La. 10/16/95), 661 So.2d 442, 443. When

the factfinder is faced with contradictory testimony, the weight of the testimony lays

solely with the jury, “who may accept or reject, in whole or in part, the testimony of

any witness.” State v. Hypolite, 04–1658, pp. 4 (La.App. 3 Cir. 6/1/05), 903 So.2d

1275, 1279, writ denied, 06–618 (La. 9/22/06), 937 So.2d 381. Thus, other than

ensuring the sufficiency evaluation standard of Jackson, “the appellate court should 3 not second-guess the credibility determination of the trier of fact,” but rather, it

should defer to the rational credibility and evidentiary determinations of the

jury. State v. Lambert, 97-64, pp. 5 (La.App. 3 Cir. 9/30/98), 720 So.2d 724, 727.

Louisiana Revised Statutes 14:32(A)(1) defines negligent homicide as “[t]he

killing of a human being by criminal negligence.” However, La.R.S. 14:20 provides,

in pertinent part:

A. A homicide is justifiable:

(1) When committed in self-defense by one who reasonably believes that he is in imminent danger of losing his life or receiving great bodily harm and that the killing is necessary to save himself from that danger.

(2) When committed for the purpose of preventing a violent or forcible felony involving danger to life or of great bodily harm by one who reasonably believes that such an offense is about to be committed and that such action is necessary for its prevention. The circumstances must be sufficient to excite the fear of a reasonable person that there would be serious danger to his own life or person if he attempted to prevent the felony without the killing.

When a homicide defendant claims self-defense, the State has the affirmative

burden of proving beyond a reasonable doubt that the homicide was not perpetrated

in self-defense; a defendant does not assume a burden of proving self-defense. State

v. Lynch, 436 So.2d 567 (La.1983). This court discussed the factors to be considered

in examining a self-defense claim in State v. Guillory, 17-403, p. 4 (La.App. 3 Cir.

10/11/17), 229 So.3d 949, 953-54, writ denied, 17-1964 (La. 6/1/18), 244 So.3d 437:

In State v. Fox, 15-692, p. 4 (La.App. 3 Cir. 2/3/16), 184 So.3d 886, 890, writ denied, 16-404 (La. 3/13/17), [216] So.3d [800], this court stated:

“In examining a self-defense claim, it is necessary to consider: (1) whether the defendant reasonably believed that he was in imminent danger of death or great bodily harm; (2) whether the killing was necessary to prevent that death or great bodily harm; and (3) whether the defendant was the aggressor in the conflict.” State v. Mayes, 14-683, 4 pp. 2-3 (La.App. 3 Cir. 12/23/14), 154 So.3d 1257, 1259, writs denied, 15-178, 15-220 (La. 11/16/15), 184 So.3d 24. Additionally, in determining whether the defendant had a reasonable belief that the killing was necessary, it is appropriate to consider “the excitement and confusion of the situation, the possibility of using force or violence short of killing, and the defendant’s knowledge of the assailant’s bad character.” State v. Thomas, 43,100, p. 5 (La.App. 2 Cir. 4/30/08), 981 So.2d 850, 854, writ denied, 08-1276 (La. 2/6/09), 999 So.2d 769.

Review of Evidence Adduced at Trial

We note at the outset that the jury was confronted with various conflicting

accounts of the events which lead to Mr. Nelson’s death and were, consequently,

called upon to resolve several factual disputes.

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Related

Jackson v. Virginia
443 U.S. 307 (Supreme Court, 1979)
State v. Thomas
981 So. 2d 850 (Louisiana Court of Appeal, 2008)
State v. Captville
448 So. 2d 676 (Supreme Court of Louisiana, 1984)
State v. Smith
661 So. 2d 442 (Supreme Court of Louisiana, 1995)
State v. Johnson
22 So. 3d 205 (Louisiana Court of Appeal, 2009)
State v. Leger
936 So. 2d 108 (Supreme Court of Louisiana, 2006)
State v. Fenner
664 So. 2d 1315 (Louisiana Court of Appeal, 1995)
State v. Hypolite
903 So. 2d 1275 (Louisiana Court of Appeal, 2005)
State v. Pigford
922 So. 2d 517 (Supreme Court of Louisiana, 2006)
State v. Lynch
436 So. 2d 567 (Supreme Court of Louisiana, 1983)
State v. Lambert
720 So. 2d 724 (Louisiana Court of Appeal, 1998)
Leger v. Louisiana
127 S. Ct. 1279 (Supreme Court, 2007)
State v. Davies
350 So. 2d 586 (Supreme Court of Louisiana, 1977)
State v. Taylor
688 So. 2d 1262 (Louisiana Court of Appeal, 1997)
State v. Dorsey
74 So. 3d 603 (Supreme Court of Louisiana, 2011)
State of Louisiana v. Christopher J. Wells
209 So. 3d 709 (Supreme Court of Louisiana, 2015)
State v. Wilkins
131 So. 3d 839 (Supreme Court of Louisiana, 2014)
State v. Mayes
154 So. 3d 1257 (Louisiana Court of Appeal, 2014)
State v. Fox
184 So. 3d 886 (Louisiana Court of Appeal, 2016)
State v. Guillory
229 So. 3d 949 (Louisiana Court of Appeal, 2017)

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