State Of Louisiana v. Michael Halford

CourtLouisiana Court of Appeal
DecidedJune 4, 2021
Docket2020KA0585
StatusUnknown

This text of State Of Louisiana v. Michael Halford (State Of Louisiana v. Michael Halford) 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. Michael Halford, (La. Ct. App. 2021).

Opinion

STATE OF LOUISIANA

COURT OF APPEAL

FIRST CIRCUIT m u 1 fILpme V5 2020 KA 0585

Jew STATE OF LOUISIANA

VERSUS

MICHAEL HALFORD

Judgment Rendered: JUN o 4 2021

Appealed from the 21st Judicial District Court In and for the Parish of St. Helena State of Louisiana Case No. 20028

The Honorable Jeffrey Johnson, Judge Presiding

Cynthia K. Meyer Counsel for Plaintiff/Appellant Louisiana Appellate Project Michael Halford New Orleans, LA

Michael Halford In proper person Angola, LA

Scott M. Perrilloux Counsel for Defendant/Appellee

District Attorney State of Louisiana Richard McShan Brett Sommer Assistant District Attorneys

Greensburg, LA

BEFORE: McCLENDON, WELCH, AND LANIER, JJ. LANIER, J.

The defendant, Michael Lynn Halford, was charged by grand jury

indictment with first degree murder, a violation of La. R.S. 14: 30. He pled not

guilty. The defendant filed a motion in limine to prohibit the use of a statement

and/ or testimony of Jessica Raymond based on spousal privilege. After a pretrial

hearing, the trial court found that no spousal privilege existed. The defendant did

not testify at trial. After a trial by jury, the defendant was found guilty as charged.

The trial court sentenced the defendant to life imprisonment at hard labor, to be

served without the benefit of probation, parole, or suspension of sentence. 1

The defendant now appeals, assigning as error in a counseled brief the trial

court' s denial of challenges for cause of several prospective jurors and the trial

court' s ruling on the motion in limine. The defendant filed a pro se brief raising

sufficiency of the evidence and supplementing the arguments raised in the

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

STATEMENT OF FACTS

On August 7, 2012, Rhonda Morris, a postal worker in Greensburg,

Louisiana, approached the driveway of John Nelson Hornsby ( the victim) while on

her mail route, and observed that his house had completely burned down. She

further noticed that the driver' s door of the victim' s truck was ajar. She walked

around to the front of the truck and saw the victim' s body lying in the grass. Ms.

Morris called the St. Helena Parish Sheriff's Office ( SHPSO) and waited for an

ambulance and the police to arrive.

Officers responded to the scene, and when they arrived, Deputy Micah

Woodard spoke to Ms. Morris as the other officers began to check and secure the

1 The State did not seek the death penalty in this case.

2 scene. Patrick Lane of the Louisiana State Police Crime Lab ( crime lab) also

arrived at the scene, took video footage, and collected evidentiary items and

samples. SHPSO detectives Laurie Sibley and Gary Cannon arrived at the scene at

approximately 10: 00 a. m. Detective Cannon photographed the scene, including the

victim, a maul or sledgehammer located near the victim' s body, and the left front

tire of the victim' s truck, which had blood and gray hair on it matching the

victim' s hair color.

Detectives Sibley and Cannon questioned neighbors in the area and learned

that noises, including loud popping and dogs, were heard that morning from about

4: 00 a.m. to about 6: 00 or 6: 30 a.m. The detectives further attended the victim' s

autopsy, collected swabs and fingernail clippings taken from the victim, and sent

the items to the crime lab for testing. After the SHPSO received verbal

communication of the crime lab results showing the defendant' s DNA was located

under the victim' s fingernails, a warrant for the defendant' s arrest was obtained

and executed.

Jessica Raymond, the defendant' s wife at the time of the offense, visited the

defendant in jail after his arrest.' Ms. Raymond testified at trial that, prior to the

jail visit, she suspected that the defendant had committed the murder. She further

testified that she held a conversation with the defendant during the jail visit in an

attempt to elicit a confession and that the defendant, in response, confirmed that he

killed the victim. The defendant then instructed Ms. Raymond to hide evidence of

the crime for him.

SUFFICIENCY OF THE EVIDENCE

In assignment of error number one of his pro se brief, the defendant argues

that the State failed to meet its burden of proof beyond a reasonable doubt of every

Ms. Raymond testified that she had recently married before the trial and that her last name at the time was Nolley. Herein, we will use Raymond, the last name given during her testimony at the pretrial hearing on the motion in limine.

3 essential element of the offense. Noting that the defendant had regularly been in

and around the victim' s residence prior to his death to do various errands for him,

the defendant argues that the State failed to prove the significance of DNA and

fingerprint evidence obtained. The defendant also contends that there was no

evidence to support the State' s theory that he was present when the victim was

murdered. He contends that the video footage shown at trial only proved that he

was at a convenience store at 3: 55 a. m., five minutes before the approximate time

of the victim' s murder. In that regard, he further contends that there was no actual

determination of the distance between the store and the victim' s residence and/ or

how long it would have taken him to drive from one location to the other.

The defendant further notes that no one witnessed him commit the murder.

He argues that " the mere presence of [his] DNA being under fingernails on the

victim' s left-hand ... in no way links him to the murder." He further argues that

the presence of his fingerprint on a revolver only shows that at some point in time,

he had touched the gun, possibly while in the presence of the victim. The

defendant contends that the State erroneously placed high reliability on Ms.

Raymond' s " questionable" allegation that he confessed to the murder. He

concludes that the State' s evidence at the most shows that he may have been

involved in a theft or burglary. Thus, he argues that the conviction should be

reversed.

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

process. See U.S. Const. amend. XIV; La. Const. art. I, § 2. In reviewing claims

challenging the sufficiency of the evidence, this court must consider 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 beyond a

reasonable doubt. See Jackson v. Virginia, 443 U.S. 307, 319, 99 S. Ct. 27811

2789, 61 L.Ed.2d 560 ( 1979). See also La. Code Crim. P. art. 821( B); State v.

4 Ordodi, 2006- 0207 ( La. 11/ 29/ 06), 946 So. 2d 654, 660. The Jackson standard of

review, incorporated in Article 821( B), is an objective standard for testing the

overall evidence, both direct and circumstantial, for reasonable doubt. When

analyzing circumstantial evidence, La. R.S. 15: 438 provides that the fact finder

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Related

Jackson v. Virginia
443 U.S. 307 (Supreme Court, 1979)
State v. Dupuy
319 So. 2d 294 (Supreme Court of Louisiana, 1975)
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557 So. 2d 1388 (Supreme Court of Louisiana, 1990)
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637 So. 2d 102 (Supreme Court of Louisiana, 1994)
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State v. Kang
859 So. 2d 649 (Supreme Court of Louisiana, 2003)
State v. Manning
885 So. 2d 1044 (Supreme Court of Louisiana, 2004)
State v. Taylor
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State v. Hallal
544 So. 2d 1222 (Louisiana Court of Appeal, 1989)
State v. Martin
558 So. 2d 654 (Louisiana Court of Appeal, 1990)
State v. Mitchell
772 So. 2d 78 (Supreme Court of Louisiana, 2000)
State v. Pinion
968 So. 2d 131 (Supreme Court of Louisiana, 2007)
State v. Davis
822 So. 2d 161 (Louisiana Court of Appeal, 2002)
State v. Patorno
822 So. 2d 141 (Louisiana Court of Appeal, 2002)
State v. Ordodi
946 So. 2d 654 (Supreme Court of Louisiana, 2006)

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