State v. Hartman

189 So. 3d 458, 2015 La.App. 1 Cir. 1023, 2016 La. App. LEXIS 245, 2016 WL 631997
CourtLouisiana Court of Appeal
DecidedFebruary 17, 2016
DocketNo. 2015 KA 1023
StatusPublished
Cited by4 cases

This text of 189 So. 3d 458 (State v. Hartman) 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 v. Hartman, 189 So. 3d 458, 2015 La.App. 1 Cir. 1023, 2016 La. App. LEXIS 245, 2016 WL 631997 (La. Ct. App. 2016).

Opinion

CRAIN, J.

|2The defendant, Joan Faye Hartman, was indicted for the second-degree murder of Tanya Carolina Knower. See La. R.S. 14:30.1. A jury found the defendant guilty of manslaughter, and the trial court sentenced her to thirty-five years imprisonment at hard labor. See La. R.S. 14:31; La.Code Crim. Pro. art. 814. The defendant appeals arguing that the State failed to prove she did not act in self-defense, that the trial court improperly instructed the jury, and that the sentence imposed is excessive. We affirm the defendant’s conviction and sentence.

FACTS AND PROCEDURAL HISTORY

On July 15, 2012, the fifty-four-year-old defendant fatally stabbed twenty-seven-year-old Tanya. Tanya was in a relationship with the defendant’s son, Richard, and was the mother of his two daughters, all of whom lived in a small home with the defendant and the defendant’s wheelchair-bound husband. The relationship between the defendant and Tanya was contentious and, at times, volatile. The defendant believed that Tanya neglected her children and family, and also abused drugs. On the night of the crime, the defendant and Tanya argued, and Tanya threatened to move out of the home with the children and never let the defendant see them again. The argument escalated to a physical confrontation, with the defendant ultimately stabbing Tanya twice, first in the back, and then in the stomach.

At trial, the defendant admitted that she killed Tanya, but claimed shp acted in self-defense. The jury rejected the defendant’s defense and found her guilty of manslaughter, which is a homicide that would be either first-degree murder or second-degree murder, but is committed in sudden passion or heat of blood immediately caused by provocation sufficient to deprive an average person of his self-control and cool reflection. See La. R.S. 14:31(A)(1).

| aSELF-DEFENSE

The defendant argues that the evidence at trial is insufficient to support a conviction of manslaughter because the State failed to prove that she did not act in self-defense. The defense contended that the defendant was the primary caregiver for everyone in the family, despite her heart condition, and did her best to keep her family together. However, the defense contended that Richard was an ungrateful liar who abused the defendant, and Tanya was “[wjhacked out” on Xanax and was “the root of every last bit of evil in [the defendant’s] life.” The defense asserted that the defendant bought a knife for her own protection because she feared that Tanya would kill her, maintaining that Tanya had stabbed her before and repeatedly threatened to do so again. The defense argued that on the night of the crime the defendant reasonably believed that Tanya was under the influence of [461]*461Xanax and was going to stab her, so the defendant was justified in retrieving her knife and defending her own life. While two knives were found at the crime scene, one brown-handled and one black-handled, the evidence at trial revealed that Tanya’s wounds were caused by the brown-handled knife. The defense argued that the logical explanation for the presence of the black-handled knife is that Tanya was' armed with it and intended to kill the defendant.

A homicide is justifiable when committed in self-defense by one who reasonably believes that she is in imminent danger of losing her life or receiving great bodily harm and that the killing is necessary to save herself from that danger. La. R.S. 14:20(A)(1). However, a person who is the aggressor or who brings on a difficulty cannot claim the right of self-defense unless she withdraws from the conflict in good faith and in such a manner that her adversary knows or should know that she desires to withdraw and discontinue the conflict. La. R.S. 14:21, When the defendant in a homicide Rprosecution claims self-defense, the State must prove beyond a reasonable doubt that the homicide was not committed in self-defense. State v. Williams, 01-0944 (La.App. 1 Cir. 12/28/01), 804 So.2d 932, 939, writ denied, 02-0399 (La.2/14/03), 836 So.2d 135.

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. 2781, 2789, 61 L.Ed.2d 560 (1979); see also La.Code Crim. Pro. art. 821(B); State v. Ordodi, 06-0207 (La.11/29/06), 946 So.2d 654, 660; State v. Mussall, 523 So.2d 1305, 1308-09 (La.1988). Regarding the defendant’s claim that she acted in self-defense, the relevant inquiry on appeal is whether, after viewing the evidence in the light most favorable to the prosecution, a rational factfinder could have found beyond a reasonable doubt that the defendant did not act in self-defense. Williams, 804 So.2d at 939.

As part of the evidence against the •defendant, the .State presented the defendant’s recorded interview with St. Tammany Parish Sheriff’s officers conducted hours after the crime. During most of the interview, the defendant was unaware that Tanya died frqm her injuries, and she repeatedly stated she hoped Tanya would die and that she preferred to go to jail for murder rather than attempted murder. The defendant said, “I hate her guts and I want her dead ... Bitch should be dead.”

During the interview, the defendant voiced numerous complaints against Tanya, including her failure to properly care for the children’s medical needs and Tanya’s threat to remove the children. She described Tanya as constantly “pushing” her. The defendant also told the officers that Tanya ^stabbed her approximately eight years previous, but the defendant lied about the source of her injuries then to protect Tanya for the children’s sake, noting that Tanya never thanked her. The defendant also indicated that Tanya frequently threatened to stab her again. She stated that the children deserved a better mother and that Tanya was “better dead.” The defendant complained about Tanya’s abuse of Xanax and reiterated that she hoped Tanya died. She told the officers “you can just push someone so far until someone says that’s enough .... I been pushed for f-years.” The defendant said that Tanya “[put her] through hell.”

Regarding the events of the evening of the crime, the defendant described arguing with Tanya then going for a walk to calm things down after Tanya called her names [462]*462and spit in her face. Upon returning, the defendant found that Tanya had removed all of the children’s drawings and pictures from the walls. The defendant was infuriated, describing Tanya’s action as “just mean.” The two then argued, and Tanya threatened to take the children away and never allow the defendant to see them. The defendant described Richard separating a physical confrontation, then the defendant going to retrieve her knife from her bedroom closet. The defendant explained that a month prior, she had purchased the knife to use against Tanya and intended to kill Tanya then, but was convinced otherwise by the defendant’s sister.

The defendant explained that after she retrieved her knife, she encountered Tanya and stabbed Tanya in the back as Tanya turned away. She said she told Tanya, “this is how it feels,” referring to the time Tanya stabbed her.

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Bluebook (online)
189 So. 3d 458, 2015 La.App. 1 Cir. 1023, 2016 La. App. LEXIS 245, 2016 WL 631997, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-hartman-lactapp-2016.