State of Louisiana v. Steven Dwayne Rigmaiden

CourtLouisiana Court of Appeal
DecidedOctober 23, 2024
DocketKA-0024-0288
StatusUnknown

This text of State of Louisiana v. Steven Dwayne Rigmaiden (State of Louisiana v. Steven Dwayne Rigmaiden) 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. Steven Dwayne Rigmaiden, (La. Ct. App. 2024).

Opinion

STATE OF LOUISIANA COURT OF APPEAL, THIRD CIRCUIT

24-288

STATE OF LOUISIANA

VERSUS

STEVEN DWAYNE RIGMAIDEN

**********

APPEAL FROM THE FOURTEENTH JUDICIAL DISTRICT COURT PARISH OF CALCASIEU, NO. 12705-21 HONORABLE G. MICHAEL CANADAY, DISTRICT JUDGE

CHARLES G. FITZGERALD JUDGE

Court composed of Candyce G. Perret, Jonathan W. Perry, and Charles G. Fitzgerald, Judges.

AFFIRMED. Annette Roach Louisiana Appellate Project Post Office Box 6547 Lake Charles, Louisiana 70606 (337) 436-2900 Counsel for Defendant/Appellant: Steven Dwayne Rigmaiden

Stephen C. Dwight District Attorney David S. Pipes Assistant District Attorney Fourteenth Judicial District 901 Lakeshore Drive, Suite 800 Lake Charles, Louisiana 70601 (337) 437-3400 Counsel for Appellee: State of Louisiana FITZGERALD, Judge.

Defendant, Steven Dwayne Rigmaiden, appeals his conviction for second

degree murder.

On June 19, 2021, Ezekiel Joubert was shot and killed in Lake Charles,

Louisiana. Two months later, Defendant was charged by Bill of Information with

the second degree murder of Mr. Joubert. Then, in June 2023, a unanimous jury

found Defendant guilty as charged.

Shortly thereafter, Defendant filed a motion for new trial, contending that the

State failed to prove that he was the person who killed Mr. Joubert. A few months

after that, Defendant filed a second motion for new trial, again attacking the

sufficiency of the State’s evidence. The trial court ultimately denied both motions.

The trial court then sentenced Defendant to a mandatory life sentence at hard labor

without benefit of probation, parole, or suspension of sentence.

Defendant now appeals his conviction. In his sole assignment of error,

Defendant asserts that the evidence was insufficient to prove beyond a reasonable

doubt that he killed Mr. Joubert.

LAW AND ANALYSIS Pursuant to La.Code Crim.P. art. 920, we initially find that there are no patent

errors on the face of the record. We now turn our attention to Defendant’s assigned

error.

Defendant’s assignment challenges the sufficiency of the evidence. A

sufficiency-of-the-evidence challenge is reviewed on appeal under the standard set

forth in Jackson v. Virginia, 443 U.S. 307, 99 S.Ct. 2781 (1979). “[T]he relevant

question 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 beyond a reasonable doubt.” Id. at 319. “This standard, now legislatively

embodied in La.C.Cr.P. art. 821, does not provide the appellate court with a vehicle

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.

In other words, 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. Rather, the reviewing court must afford great deference to a jury’s

decision to accept or reject the testimony. State v. Allen, 36,180 (La.App. 2 Cir.

9/18/02), 828 So.2d 622, writs denied, 02-2595 (La. 3/28/03), 840 So.2d 566, and

02-2997 (La. 6/27/03), 847 So.2d 1255, cert. denied, 540 U.S. 1185, 124 S.Ct. 1404

(2004). “Where there is conflicting testimony about factual matters, the resolution

of which depends upon a determination of the credibility of the witnesses, the matter

is one of the weight of the evidence, not its sufficiency.” Id. at 626.

Summary of the Trial Evidence

The State’s first witness was Michael Rachal. He was the supervisor of

computer information systems at Calcasieu 911. In conjunction with his testimony,

a thumb drive containing three 911 calls related to the June 19, 2021 shooting of Mr.

Joubert was admitted into evidence.

The first call was received at 8:25 p.m. on June 19, 2021. This call was made

by Mike Landry, who reported that he heard gunshots, went outside, and saw a man

lying in the grass, bleeding. The second call came from Brett Joseph, and it was also

received at 8:25 p.m. In this call, Mr. Joseph reported that he heard about four

gunshots and then saw an individual lying motionless on the sidewalk. The third

and final call was made at 8:26 p.m., but it was simply a transfer call between 911

and local law enforcement.

2 The State’s next witness was Detective Russell Mixon of the Lake Charles

Police Department. Detective Mixon testified that on the evening of June 19, 2021,

he was dispatched to the intersection of Albert Street and Elder Street. He stopped

his vehicle just short of the intersection because a bag was sitting in the middle of

Albert Street. He then exited his vehicle and observed individuals on the side of the

road pointing toward the intersection. Thereafter, Detective Mixon found “an

individual motionless, unresponsive and in a fixed position.”

The video recording from Detective Mixon’s body camera was also admitted

into evidence. And it shows that when Detective Mixon steps out of his vehicle, a

bystander tells him to look for “a red Monte Carlo.” After checking on the victim,

Detective Mixon tells the spectators to stay close so he can get their information but

asks them to back up so he can mark off the crime scene. A few minutes later,

additional officers arrive at the scene from two different directions. The recording

shows Detective Mixon giving instructions to these officers. One minute later,

Acadian Ambulance medical technicians can be seen checking on the victim. And

ten minutes after that, the victim is identified over the radio as Ezekiel Joubert. The

body-camera footage also shows a bystander telling Detective Mixon that she heard

three gunshots less than twenty minutes earlier.

The next witness was Brett Joseph. Mr. Joseph testified that he had lived in

Calcasieu Parish for about thirty years and that his residence was on Albert Street in

June 2021. He acknowledged having called 911 on June 19, 2021. According to

Mr. Joseph, he was sitting on his porch, which is about forty to fifty feet away from

where the victim was ultimately found.

As to the shooting, Mr. Joseph recalled that the victim was walking east on

Elder Street. And at the same time, a car was traveling north on Albert Street. Then,

3 at the intersection of Elder and Albert Streets, the victim approached the car “like he

knew him.” Mr. Joseph explained that the victim was carrying a bag and that he

approached the driver’s side window of the car. Mr. Joseph next heard multiple

pops, which he initially believed were fireworks. He then saw the victim jump and

run away from the car which sped off heading north. Mr. Joseph explained that he

did not see the victim in the grass and did not realize the man had been shot until

sometime later.

Mr. Joseph identified the vehicle in question as a red Chevrolet—either a

Monte Carlo or Impala—noting that his memory was not “all the way accurate on

what [he could] remember.” He then explained that the windows of the car were

dark, making it impossible for him to see who was driving.

On cross-examination, Mr. Joseph acknowledged that he did not know how

many people were in the car because the windows were up when it passed his house.

And although Mr. Joseph did not know the victim personally, he did recognize him

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Related

Jackson v. Virginia
443 U.S. 307 (Supreme Court, 1979)
State v. Captville
448 So. 2d 676 (Supreme Court of Louisiana, 1984)
State v. Allen
828 So. 2d 622 (Louisiana Court of Appeal, 2002)
State v. Smith
661 So. 2d 442 (Supreme Court of Louisiana, 1995)
Draughn v. Louisiana
128 S. Ct. 537 (Supreme Court, 2007)
State v. Pigford
922 So. 2d 517 (Supreme Court of Louisiana, 2006)
State v. Wright
445 So. 2d 1198 (Supreme Court of Louisiana, 1984)
State v. Sutton
436 So. 2d 471 (Supreme Court of Louisiana, 1983)
State v. Graham
422 So. 2d 123 (Supreme Court of Louisiana, 1982)
State v. Draughn
950 So. 2d 583 (Supreme Court of Louisiana, 2007)
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. Baumberger
200 So. 3d 817 (Louisiana Court of Appeal, 2016)
State v. Burns
441 So. 2d 843 (Louisiana Court of Appeal, 1983)

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State of Louisiana v. Steven Dwayne Rigmaiden, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-louisiana-v-steven-dwayne-rigmaiden-lactapp-2024.