State of Louisiana v. Michael J. Worley

CourtLouisiana Court of Appeal
DecidedAugust 3, 2022
DocketKA-0021-0688
StatusUnknown

This text of State of Louisiana v. Michael J. Worley (State of Louisiana v. Michael J. Worley) 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 J. Worley, (La. Ct. App. 2022).

Opinion

STATE OF LOUISIANA

COURT OF APPEAL, THIRD CIRCUIT

21-688

VERSUS

MICHAEL J. WORLEY

**********

APPEAL FROM THE TWENTY-EIGHTH JUDICIAL DISTRICT COURT PARISH OF LASALLE, NO. 14-563 HONORABLE J. CHRISTOPHER PETERS, DISTRICT JUDGE

JONATHAN W. PERRY JUDGE

Court composed of Elizabeth A. Pickett, Candyce G. Perret, and Jonathan W. Perry, Judges.

AFFIRMED. Chad M. Ikerd Ikerd Law Firm, LLC Louisiana Appellate Project Post Office Box 2125 Lafayette, Louisiana 70502 (337) 366-8994 COUNSEL FOR DEFENDANT/APPELLANT: Michael J. Worley

J. Reed Walters District Attorney, Twenty-Eighth Judicial District Steven P. Kendrick Assistant District Attorney Post Office Box 1940 Jena, Louisiana 70601 (318) 992-8282 COUNSEL FOR APPELLEE: State of Louisiana PERRY, Judge.

Defendant, Michael J. Worley, appeals his conviction for second-degree

murder, a violation of La.R.S. 14:30.1, for which he received a sentence of life at

hard labor without benefit of parole, probation, or suspension of sentence. For the

following reasons, we affirm Defendant’s conviction.

FACTS AND PROCEDURAL HISTORY

On May 14, 2014, Defendant, Michael J. Worley, was charged by grand jury

indictment with the second-degree murder of his wife, Mary. Pursuant to a motion

filed by defense counsel, on February 20, 2015, the trial court appointed a sanity

commission to determine Defendant’s capacity to understand the proceedings and to

determine Defendant’s mental condition at the time of the offense. On January 7,

2016, the trial court found Defendant competent to proceed. After a five-day trial in

May 2016, a unanimous jury found Defendant guilty of second-degree murder on

May 27, 2016. Immediately after the jury’s verdict, the trial court ordered a

presentence investigation and set sentencing for July 5, 2016. On the date of

sentencing, defense counsel orally moved for a post-verdict judgment of acquittal,

which the trial court denied. The trial court then imposed a sentence of life

imprisonment at hard labor without benefit of parole, probation, or suspension of

sentence.

Finding the trial court granted Defendant an out-of-time appeal by granting

his application for post-conviction relief, this court ordered the trial court to prepare

an appellate record and submit it to this court. State v. Worley, 21-444 (La.App. 3

Cir. 8/4/21) (unpublished opinion), writ denied, 21-1206 (La. 1/12/22), 330 So.3d

611. Now before the court is a brief filed by Defendant, solely alleging the evidence was insufficient to convict him of second-degree murder. For the reasons discussed,

we find Defendant’s assignment of error lacks merit.

ERRORS PATENT

As required by La.Code Crim.P. art. 920, this court reviews all appeals for

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

harmless error.

The trial court sentenced Defendant immediately after it denied Defendant’s

oral motion for post-verdict judgment of acquittal. Louisiana Code of Criminal

Procedure Article 873 provides, in pertinent part:

If a motion for a new trial, or in arrest of judgment, is filed, sentence shall not be imposed until at least twenty-four hours after the motion is overruled. If the defendant expressly waives a delay provided for in this article or pleads guilty, sentence may be imposed immediately.

Since La.Code Crim.P. art. 873 does not mention a motion for post-verdict

judgment of acquittal, it is questionable whether a twenty-four-hour delay is required

after the denial of such motion.

In State v. Boyance, 05-1068 (La.App. 3 Cir. 3/1/06), 924 So.2d 437, writ

denied, 06-1285 (La. 11/22/06), 942 So.2d 1103, this court applied the

twenty-four-hour delay to a motion for post-verdict judgment of acquittal but found

the error was harmless since the defendant had not challenged the excessiveness of

his sentence. See, e.g., State v. Shepherd, 02-1006 (La.App. 3 Cir. 3/5/03), 839

So.2d 553; State v. Roberts, 13-1064 (La.App. 3 Cir. 3/5/14) (unpublished opinion);

and State v. Sherman, 11-1042 (La.App. 3 Cir. 4/4/12) (unpublished opinion), writ

denied, 12-1433 (La. 1/11/13), 106 So.3d 547.

In this case, Defendant does not argue excessiveness of his sentence on appeal,

and he does not claim he was prejudiced by the lack of delay. Therefore, even

2 assuming the delay applies, we find that any possible error in this respect is harmless

because Defendant neither contests his sentence nor argues prejudice from the trial

court’s immediate sentencing.

LAW AND DISCUSSION

Defendant alleges the State failed to prove he killed his wife when there was

no forensic evidence, no direct evidence, and no eyewitness testimony. According

to Defendant, the State’s case relied on “weak circumstantial coincidences.”

The following jurisprudence sets forth the standard of review in this case:

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 (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 credibilities of the witnesses, and therefore, the appellate court should not second guess the credibility determinations of the trier of fact beyond the sufficiency evaluations under the Jackson standard of review. See Graffagnino, 436 So.2d at 563, citing State v. Richardson, 425 So.2d 1228 (La.1983). To obtain a conviction, the elements of the crime must be proven beyond a reasonable doubt.

State v. Thacker, 13-516, p. 5 (La.App. 3 Cir. 1/28/15), 157 So.3d 798, 804 (quoting

State v. Freeman, 01-997, pp. 2-3 (La.App. 3 Cir. 12/12/01), 801 So.2d 578, 580).

As for appellate review in cases relying on circumstantial evidence, this court

has stated the following:

When the conviction is based upon circumstantial evidence, La.R.S. 15:438 provides that the state “must exclude every reasonable hypothesis of innocence” in order to convict. State v. Camp, 446 So.2d 1207, 1209 (La.1984). “Circumstantial evidence consists of proof of collateral facts and circumstances from which elemental factors may be inferred according to reason, experience and common sense.” State v. Burns, 441 So.2d 843, 845 (La.App. 3 Cir.1983). However, La.R.S.

3 15:438 does not establish a stricter standard of review on appeal than the rational juror’s reasonable doubt standard. The statute serves as a guide for the jury when considering circumstantial evidence. On appeal, the issue is whether a rational trier of fact, when viewing the evidence in a light most favorable to the prosecution, could find that all reasonable hypotheses of innocence were excluded. State v. Williams, 13-497 (La.App. 3 Cir. 11/6/13), 124 So.3d 1236, writ denied, 13-2774 (La. 5/16/14), 139 So.3d 1024.

State v. Baumberger, 15-1056, pp. 10-11 (La.App. 3 Cir. 6/1/16), 200 So.3d 817,

826-27, writ denied, 16-1251 (La. 5/26/17), 221 So.3d 859, cert. denied, 138

S.Ct. 392 (2017).

Evidence at Trial

The first witness to testify for the State was Jessica Dorsey, a Communications

Deputy with the Rapides Parish Sheriff’s Office. Deputy Dorsey testified that on

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

Related

Jackson v. Virginia
443 U.S. 307 (Supreme Court, 1979)
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. Richardson
425 So. 2d 1228 (Supreme Court of Louisiana, 1983)
State v. Robertson
680 So. 2d 1165 (Supreme Court of Louisiana, 1996)
State v. Pigford
922 So. 2d 517 (Supreme Court of Louisiana, 2006)
State Ex Rel. Graffagnino v. King
436 So. 2d 559 (Supreme Court of Louisiana, 1983)
Wimberly v. State
839 So. 2d 553 (Court of Appeals of Mississippi, 2002)
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. Boyance
924 So. 2d 437 (Louisiana Court of Appeal, 2006)
State v. Freeman
801 So. 2d 578 (Louisiana Court of Appeal, 2001)
State v. Camp
446 So. 2d 1207 (Supreme Court of Louisiana, 1984)
State v. Williams
124 So. 3d 1236 (Louisiana Court of Appeal, 2013)
State v. Mack
144 So. 3d 983 (Supreme Court of Louisiana, 2014)
State v. Thacker
157 So. 3d 798 (Louisiana Court of Appeal, 2015)
State v. Baumberger
200 So. 3d 817 (Louisiana Court of Appeal, 2016)
State v. Burns
441 So. 2d 843 (Louisiana Court of Appeal, 1983)

Cite This Page — Counsel Stack

Bluebook (online)
State of Louisiana v. Michael J. Worley, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-louisiana-v-michael-j-worley-lactapp-2022.