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State v. Alexander

Citations: 182 So. 3d 126; 2014 La.App. 1 Cir. 1619; 2015 La. App. LEXIS 1741; 2015 WL 5474858Docket: No. 2014 KA 1619

Court: Louisiana Court of Appeal; September 18, 2015; Louisiana; State Appellate Court

Narrative Opinion Summary

The case involves an appeal following the conviction of the defendant for attempted forcible rape after originally being charged with attempted aggravated rape. The incident occurred when the defendant, having performed repair work at the victim's residence, overpowered her despite her resistance, leading to his conviction based on both direct and circumstantial evidence, including DNA findings. The defendant challenged the sufficiency of the evidence, arguing that the lack of physical evidence and the nature of the victim's injuries did not support the conviction. However, the court applied the Jackson v. Virginia standard, affirming the conviction by finding that a rational trier of fact could establish guilt beyond a reasonable doubt. The court noted that circumstantial evidence must exclude every reasonable hypothesis of innocence as per Louisiana law. The victim's testimony, supported by DNA evidence and photographs of her injuries, was deemed credible. The jury's reliance on the victim's account and rejection of the defendant's hypothesis of innocence led to the affirmation of the conviction and the sentence of twenty years in prison, with eighteen years suspended and five years of probation.

Legal Issues Addressed

Attempted Crime under Louisiana Law

Application: The court evaluated whether the defendant's actions demonstrated specific intent and an act towards the commission of forcible rape.

Reasoning: To convict for attempted forcible rape, the State must demonstrate the defendant's specific intent to commit the crime, alongside an act directly aimed at achieving that goal, as outlined in La. R.S. 14:27 and 14:42.1.

Credibility and Sufficiency of Victim Testimony

Application: The court emphasized that the victim's credible testimony alone, if believed, can establish the elements of the offense.

Reasoning: Her testimony alone, if believed, can establish the offense's elements.

Definition and Elements of Forcible Rape under Louisiana Law

Application: The court considered the statutory definition of forcible rape, requiring the victim's inability to resist due to force or threats, in determining the sufficiency of evidence.

Reasoning: Forcible rape occurs when the victim cannot resist due to force or threats, according to La. R.S. 14:42.1A(1).

Sufficiency of Evidence Under Jackson v. Virginia

Application: The court applied the Jackson v. Virginia standard to assess whether a rational trier of fact could find the elements of attempted forcible rape proven beyond a reasonable doubt.

Reasoning: The court reviewed the evidence under the Jackson v. Virginia standard, which assesses whether a rational trier of fact could find the elements of the crime proven beyond a reasonable doubt.

Use of Circumstantial Evidence in Criminal Convictions

Application: The court evaluated the circumstantial evidence, which must exclude every reasonable hypothesis of innocence, to affirm the conviction.

Reasoning: In Louisiana, circumstantial evidence must exclude every reasonable hypothesis of innocence per Louisiana Revised Statute 15:438.