State Of Louisiana v. Tyler J. Jackson

CourtLouisiana Court of Appeal
DecidedFebruary 23, 2024
Docket2023KA0781
StatusUnknown

This text of State Of Louisiana v. Tyler J. Jackson (State Of Louisiana v. Tyler J. Jackson) 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. Tyler J. Jackson, (La. Ct. App. 2024).

Opinion

STATE OF LOUISIANA COURT OF APPEAL FIRST CIRCUIT

DOCKET NUMBER 2023 KA 0781

STATE OF LOUISIANA

VERSUS

TYLER J. JACKSON

Judgment Rendered: FEB 2 3 2024

ON APPEAL FROM THE EIGHTEENTH JUDICIAL DISTRICT COURT, DIVISION C U IN AND FOR THE PARISH OF IBERVILLE STATE OF LOUISIANA DOCKET NUMBER 629- 18

HONORABLE ALVIN BATISTE, JR., JUDGE PRESIDING

Prentice L. White Attorney for Defendant -Appellant Baton Rouge, Louisiana Tyler J. Jackson

Antonio M. " Tony" Clayton Attorneys for Plaintiff -Appellee District Attorney State of Louisiana Terri Russo Lacy Assistant District Attorney Port Allen, Louisiana

BEFORE: THERIOT, PENZATO, AND GREENE, JJ. GREENE, J.

A grand jury indicted the defendant, Tyler Jackson, with one count of second degree

murder, a violation of La. R.S. 14: 30. 1. He pled not guilty and, following a jury trial, the

jury found him guilty as charged. The trial court denied the defendant's motion for new

trial and sentenced him to life imprisonment at hard labor without the benefit of parole,

probation, or suspension of sentence. The defendant now appeals, challenging the

sufficiency of the evidence and the trial court's failure to remove a juror. For the following

reasons, we affirm the conviction and sentence.

FACTS

On the evening of April 7, 2018, the victim, Thailan Cutno, attended a party at the

White Castle Community Center ( WCCC) with his friends Christian Harding and Henry

Broden, III. While the group was in the gymnasium, an individual ran up and hit Mr. Cutno

on the head with a gun and then shot him in the chest and back, killing him.

A few hours after the shooting, detectives with the Iberville Parish Sheriff's Office

IPSO) interviewed Mr. Harding and Mr. Broden, who provided a description of the

perpetrator. Upon receiving information that the defendant was responsible for the

shooting, detectives generated a photographic lineup containing the defendant's

photograph, which they presented to Mr. Broden. Mr. Broden positively identified the

defendant as the shooter, and officers ultimately arrested and charged the defendant with

Mr. Cutno's murder.

SUFFICIENCY OF THE EVIDENCE

In his first assignment of error, the defendant argues the evidence presented at trial

was insufficient to support his conviction for second degree murder.

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, an appellate court must determine whether any rational trier of

fact could have found the essential elements of the crime and the defendant's identity

proven beyond a reasonable doubt based on the entirety of the evidence, when viewed in

the light most favorable to the prosecution. See La. C. Cr. P. art. 821( B); Jackson v. Virginia,

443 U. S. 307, 319, 99 S. Ct. 2781, 2789, 61 L. Ed. 2d 560 ( 1979); State v. Southall, 2022-

N 0746 ( La. App. 1 Cir. 6/ 2/ 23), 369 So -3d 925, 930. When analyzing circumstantial evidence,

La. R. S. 15: 438 provides that the factfinder must be satisfied that the overall evidence

excludes every reasonable hypothesis of innocence. Southall, 369 So. 3d at 930.

The due process standard does not require the reviewing court to determine whether

it believes the witnesses or whether it believes the evidence establishes guilt beyond a

reasonable doubt. State v. Mire, 2014- 2295 ( La. 1/ 27/ 16), 269 So. 3d 698, 703 ( per curiatn).

Rather, appellate review is limited to determining whether the facts established by the direct

evidence, and inferred from the circumstances established by that evidence, are sufficient

for any rational trier of fact to conclude beyond a reasonable doubt that the defendant was

guilty of every essential element of the crime. State v. Livous, 2018- 0016 ( La. App. 1 Cir.

9/ 24/ 18), 259 So. 3d 1036, 1040, writ denied, 2018- 1788 ( La. 4/ 15/ 19), 267 So. 3d 1130.

The weight given evidence is not subject to appellate review; therefore, an appellate court

will not reweigh evidence to overturn a factfinder's determination of guilt. Id.

Second degree murder is pertinently defined as the killing of a human being when

the offender has a specific intent to kill or to inflict great bodily harm. La. R. S. 14: 30. l(A)( 1).

Specific intent is that state of mind which exists when the circumstances indicate that the

offender actively desired the prescribed criminal consequences to follow his act or failure to

act. La. R. S. 14: 10( 1). The State bears the burden of proving these statutory elements, as

well as the burden of proving the identity of the defendant as the perpetrator. State v.

Draughn, 2005- 1825 ( La. 1/ 17/ 07), 950 So. 2d 583, 593, cert. denied, 552 U. S. 1012, 128

S. Ct. 537, 169 L. Ed. 2d 377 ( 2007). When the key issue is the defendant's identity as the

perpetrator, rather than whether the crime was committed, the State is required to negate

any reasonable probability of misidentification. State v. Weary, 2003-3067 ( La. 4/ 24/ 06).

931 So. 2d 297, 311, cert denied, 549 U. S. 1062, 127 S. Ct. 682, 166 L. Ed. 2d 531 ( 2006). A

positive identification by only one witness is sufficient to support a conviction. Id In this

case, the defendant only challenges the evidence insofar it relates to his identity as the

perpetrator, not the elements of the offense.

Mr. Harding testified that he arrived at the party with Mr. Cutno and Mr. Broden at

around 10 or 11 p. m. Upon entering the gymnasium, they headed towards the middle of

the floor. A video from Mr. Harding's cell phone was introduced into evidence; the video

3 depicted Mr. Broden and Mr. Cutno in the foreground, as well as the lighting conditions in

the gymnasium. After approximately 10 to 15 minutes, they entered the lobby, where Mr.

Cutno spoke with his cousin, Tremecia Porter. Mr. Harding testified that, after the group

went back into the gymnasium about 10 minutes later, an individual ran up and hit Mr.

Cutno on the head with a gun twice. Mr. Harding and Mr. Broden punched the attacker,

who then aimed the gun at them, then directly at Mr. Cutno, and fired two shots. Mr.

Harding testified that, although part of the gymnasium was dark, the area where Mr. Cutno

was shot was near a door where light was coming in, which allowed him to see the shooter's

face.' Mr. Harding admitted that when interviewed by officers after the shooting, he

incorrectly identified himself as " Christopher Hardin" and stated it was too dark to see the

shooter's face. However, he told officers that the shooter's hairstyle was dreads and he was

shorter than 6T' tall, which matched the description of the defendant, who had dreads and

was 5' 11" tall. 2 At trial, Mr. Harding identified the defendant as the person who shot Mr.

Cutno.

Mr. Broden testified that he attended the party with Mr. Cutno and Mr. Harding,

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

Related

Remmer v. United States
347 U.S. 227 (Supreme Court, 1954)
Duncan v. Louisiana
391 U.S. 145 (Supreme Court, 1968)
Jackson v. Virginia
443 U.S. 307 (Supreme Court, 1979)
State v. Fuller
454 So. 2d 119 (Supreme Court of Louisiana, 1984)
State v. Weary
931 So. 2d 297 (Supreme Court of Louisiana, 2006)
Draughn v. Louisiana
128 S. Ct. 537 (Supreme Court, 2007)
State v. Calloway
1 So. 3d 417 (Supreme Court of Louisiana, 2009)
State v. Maillian
464 So. 2d 1071 (Louisiana Court of Appeal, 1985)
State v. Colbert
990 So. 2d 76 (Louisiana Court of Appeal, 2008)
State v. Sinegal
393 So. 2d 684 (Supreme Court of Louisiana, 1981)
Weary v. Louisiana
127 S. Ct. 682 (Supreme Court, 2006)
State v. Cass
356 So. 2d 396 (Supreme Court of Louisiana, 1977)
State v. Draughn
950 So. 2d 583 (Supreme Court of Louisiana, 2007)
State v. Ordodi
946 So. 2d 654 (Supreme Court of Louisiana, 2006)
State v. Dorsey
74 So. 3d 603 (Supreme Court of Louisiana, 2011)
State of Louisiana v. Quint Mire
269 So. 3d 698 (Supreme Court of Louisiana, 2016)
State v. Williams
54 So. 3d 1129 (Louisiana Court of Appeal, 2010)
State v. State, 2008-1991 (La. 5/15/09)
8 So. 3d 579 (Supreme Court of Louisiana, 2009)
State v. Cockerham
245 So. 3d 1035 (Supreme Court of Louisiana, 2018)
State v. Coleman
249 So. 3d 872 (Louisiana Court of Appeal, 2018)

Cite This Page — Counsel Stack

Bluebook (online)
State Of Louisiana v. Tyler J. Jackson, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-louisiana-v-tyler-j-jackson-lactapp-2024.