State of Louisiana v. Joseph Michael Elie, III

CourtLouisiana Court of Appeal
DecidedDecember 8, 2021
DocketKA-0021-0118
StatusUnknown

This text of State of Louisiana v. Joseph Michael Elie, III (State of Louisiana v. Joseph Michael Elie, 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. Joseph Michael Elie, III, (La. Ct. App. 2021).

Opinion

NOT DESIGNATED FOR PUBLICATION

STATE OF LOUISIANA COURT OF APPEAL, THIRD CIRCUIT

KA 21-118

STATE OF LOUISIANA

VERSUS

JOSEPH MICHAEL ELIE, III

**********

APPEAL FROM THE NINTH JUDICIAL DISTRICT COURT PARISH OF RAPIDES, NO. 344,498 HONORABLE MARY LAUVE DOGGETT, DISTRICT JUDGE

BILLY H. EZELL JUDGE

Court composed of Billy H. Ezell, John E. Conery, and Van H. Kyzar, Judges.

AFFIRMED J. Phillip Terrell, Jr. District Attorney Catherine L. Davidson Assistant District Attorney Ninth Judicial District P.O. Box 7358 Alexandria, LA 71306-7358 (318) 473-6650 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: Joseph Michael Elie, III

Joseph Michael Elie, III River Bend Detention Center 9450 Hwy 65 South Lake Providence, LA 71254 EZELL, Judge.

Defendant, Joseph Michael Elie, III, was charged by bill of information filed

on July 9, 2019, with second degree battery, a violation of La.R.S. 14:34.1. Trial

by jury commenced on January 7, 2020, and Defendant was found guilty as

charged on January 9, 2020. On August 17, 2020, Defendant was sentenced to

serve seven years at hard labor.

A “Notice of Appeal with Designation of Record and Motion to Appoint

Appellate Counsel” was filed on September 18, 2020. The record was lodged with

this court on February 10, 2021. Defendant now asserts, in his counsel-filed claim,

that the State failed to prove he inflicted serious bodily injury upon the victim. He

also asserts, pro se, that the victim’s testimony conflicts with cell phone location

data. These claims lack merit.

FACTS

The Defendant was convicted of committing a second-degree battery upon

Jasmine Duncatel.

ERRORS PATENT

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

errors patent on the face of the record. After reviewing the record, we find there

are no errors patent.

ASSIGNMENTS OF ERROR

In his counsel-filed assignment of error, Defendant contends the State failed

to sufficiently prove that he was guilty of second-degree battery because it failed to

prove he inflicted serious bodily injury. Counsel for Defendant acknowledges that

the victim, Jasmine Duncatel, testified he punched her and slammed her head into

the hood of a car, among other things, and did so without her consent. Thus, the evidence was sufficient as to identity and the fact that a battery took place.

However, counsel asserts the facts do not support a finding that Duncatel suffered

serious bodily injury.

In his pro se brief, Defendant contends the victim’s testimony that the

altercation took place on Madeline Street conflicts with cell phone location data

and cannot be relied on to establish that an altercation took place on September 9,

2018, on Madeline Street. Defendant argues that location data did not place him

on Madeline Street or other streets near that location, creating a conflict with Ms.

Duncatel’s testimony. Thus, there is a reasonable doubt that he ever made contact

with Ms. Duncatel.

As both assignments of error relate to the sufficiency of the evidence, this

court will address them collectively.

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, 167 L.Ed.2d 100 (2007) (citing Jackson v. Virginia, 443 U.S. 307, 99 S.Ct. 2781, 61 L.Ed.2d 560 (1979); State v. Captville, 448 So.2d 676 (La.1984) ). The Jackson standard of review is now legislatively embodied in La.Code Crim.P. art. 821. It 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 (citing State v. Robertson, 96-1048 (La. 10/4/96), 680 So.2d 1165; State v. Lubrano, 563 So.2d 847 (La.1990) ). The appellate court’s function is not to assess the credibility of witnesses or to reweigh the evidence. State v. Smith, 94-3116 (La. 10/16/95), 661 So.2d 442.

The factfinder’s role is to weigh the credibility of witnesses. State v. Ryan, 07-504 (La.App. 3 Cir. 11/7/07), 969 So.2d 1268. Thus, other than insuring the sufficiency evaluation standard of Jackson, “the appellate court should 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. Id. at

2 1270 (quoting State v. Lambert, 97-64, pp. 4-5 (La.App. 3 Cir. 9/30/98), 720 So.2d 724, 726-27). Our supreme court has stated:

However, an appellate court may impinge on the fact finder’s discretion and its role in determining the credibility of witnesses “only to the extent necessary to guarantee the fundamental due process of law.” State v. Mussall, 523 So.2d 1305, 1310 (La.1988). In determining the sufficiency of the evidence supporting a conviction, an appellate court must preserve “ ‘the factfinder’s role as weigher of the evidence’ by reviewing ‘all of the evidence . . . in the light most favorable to the prosecution.’ ” McDaniel v. Brown, 558 U.S. 120, 133– 34, 130 S.Ct. 665, 674, 175 L.Ed.2d 582 [ (2010) ] (quoting Jackson v. Virginia, 443 U.S. 307, 319, 99 S.Ct. 2781, 2789, 61 L.Ed.2d 560 (1979) ). When so viewed by an appellate court, the relevant question is whether, on the evidence presented at trial, “any rational trier of fact could have found the essential elements of the crime beyond a reasonable doubt.” Jackson, 443 U.S. at 319, 99 S.Ct. at 2789. Applied in cases relying on circumstantial evidence, . . . this fundamental principle of review means that when a jury “reasonably rejects the hypothesis of innocence presented by the defendant[ ], that hypothesis falls, and the defendant is guilty unless there is another hypothesis which raises a reasonable doubt.” State v. Captville, 448 So.2d 676, 680 (La.1984).

State v. Strother, 09-2357, pp. 10-11 (La. 10/22/10), 49 So.3d 372, 378.

State v. Bias, 18-268, 18-665, pp. 2-3 (La.App. 3 Cir. 2/6/19), 265 So.3d 821, 822-

23 (alterations in original), writ denied, 19-416 (La. 4/22/19), 268 So.3d 300.

Defendant . . . contends the injuries he inflicted . . . do not rise to the level of serious bodily injury within the definition of La.R.S. 14:34.1. To sustain a conviction for second degree battery under the statute, the State must prove beyond a reasonable doubt the injury inflicted “involved unconsciousness, extreme physical pain or protracted and obvious disfigurement, or protracted loss or impairment of the function of a bodily member, organ, or mental faculty, or a substantial risk of death.” Id. The term extreme physical pain refers to a condition which most people of common intelligence can understand. State v. Thompson, 399 So.2d 1161, 1168 (La.1981). It is considered subjective in nature and susceptible to interpretation. Id.

3 State v. Jackson, 02-1250, pp. 3-4 (La.App. 3 Cir. 2/5/03), 838 So.2d 841, 844,

writ denied, 03-832 (La. 10/17/03), 855 So.2d 759.

Corporal Huy Le responded to the complaint from Ms. Duncatel, who was

eight months pregnant, on September 9, 2018, at 6:48 p.m. Ms.

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

Related

McDaniel v. Brown
558 U.S. 120 (Supreme Court, 2010)
Jackson v. Virginia
443 U.S. 307 (Supreme Court, 1979)
State v. Jackson
838 So. 2d 841 (Louisiana Court of Appeal, 2003)
State v. Mussall
523 So. 2d 1305 (Supreme Court of Louisiana, 1988)
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. Leger
936 So. 2d 108 (Supreme Court of Louisiana, 2006)
State v. Thompson
399 So. 2d 1161 (Supreme Court of Louisiana, 1981)
State v. Lubrano
563 So. 2d 847 (Supreme Court of Louisiana, 1990)
State v. Pigford
922 So. 2d 517 (Supreme Court of Louisiana, 2006)
State v. Lambert
720 So. 2d 724 (Louisiana Court of Appeal, 1998)
State v. Ryan
969 So. 2d 1268 (Louisiana Court of Appeal, 2007)
Leger v. Louisiana
127 S. Ct. 1279 (Supreme Court, 2007)
State v. Strother
49 So. 3d 372 (Supreme Court of Louisiana, 2010)

Cite This Page — Counsel Stack

Bluebook (online)
State of Louisiana v. Joseph Michael Elie, III, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-louisiana-v-joseph-michael-elie-iii-lactapp-2021.