Court: Louisiana Court of Appeal; January 17, 1989; Louisiana; State Appellate Court
Defendant Johnny B. Wright was indicted for aggravated rape and aggravated burglary, found guilty on both counts, and sentenced to life imprisonment without parole for the rape and 30 years for the burglary, with the sentences running consecutively. Wright appealed, arguing that the trial court erred in denying his motion for acquittal and claimed the evidence was insufficient to prove guilt beyond a reasonable doubt. The victim testified that she was assaulted at knife point in her home, where the defendant vaginally raped her and left evidence of the crime. Wright presented an alibi and challenged the credibility of the victim’s identification, suggesting bias from a witness. He also argued that medical evidence did not confirm penetration or his identity as the attacker. The court referenced the legal standards for reviewing evidence sufficiency, affirming that the prosecution presented enough evidence for a rational jury to find Wright guilty beyond a reasonable doubt. The definitions of rape and aggravated rape, as well as the elements of aggravated burglary, were cited to support the verdict.
On June 14, 1986, the victim, residing at 2935 Willie Mays Street in Caddo Parish, was attacked around 1:00 a.m. while in bed. An assailant, armed with a knife, covered her mouth and threatened to kill her if she screamed. Despite her struggles, he pulled her from the bed, forced her into the living room, and raped her, ejaculating onto a pillowslip which he took when he left. The victim, dressed in a black slip she had washed the previous day, noted the time after the assault ended was between 1:20 and 1:25 a.m. She then took her children to a neighbor's house to call the police and identified the defendant, Johnny B. Wright, as her attacker, aided by the light from her children's bedroom. Her son recognized the defendant on top of his mother, having seen him in the neighborhood before, while one daughter also identified him. The youngest daughter recalled seeing a man with a black shirt during the ordeal but was uncertain in a photographic lineup. Witness Georgia Lee confirmed seeing the defendant near the victim’s home the day before the attack, noting he wore a distinctive black t-shirt. Medical examination by Dr. Dawn Knight revealed no injuries or evidence of sperm, leading to inconclusive findings regarding sexual intercourse.
Corporal Alice Mitchell interviewed the victim around 2:15 a.m., finding her distressed and reporting that her assailant was armed with a knife and screwdriver, allegedly entering through a kitchen window. The victim recognized the assailant from earlier that day. Detective A.J. Price, who interviewed the victim and her children at 2:30 a.m., confirmed the entry point via the kitchen window, noting debris consistent with items from the kitchen sink. A screwdriver was discovered on the loveseat. Sergeant Jim Derrick searched for fingerprints but found none due to unsuitable surfaces.
Pamela Smart from the North Louisiana Crime Lab examined the victim’s rape kit and gown, detecting seminal acid phosphatase, which matched the defendant's type O secretor but found no spermatozoa or foreign hairs. Defense witnesses Rodney Smith and Essie Daniels testified that the defendant was with them at Daniels' house from around 10:00 p.m. until 2:00 a.m. on the night of the attack. The defendant, who had been living in Dallas, stated he returned to Shreveport to see his sick father and had passed the victim’s house multiple times, claiming the victim had previously confronted him about being labeled a rapist and burglar.
The defendant denied owning a specific shirt mentioned in the investigation and asserted it took 15 minutes to walk from the location he was at to the victim's residence. After hearing of the accusations, he left for Dallas the next day. Detective Price rebutted that Essie Daniels could not provide an alibi for the defendant when questioned multiple times, and indicated it was only a five to seven minute walk from the victim's home to Daniels' residence. The evidence was deemed sufficient to support the defendant's convictions when viewed in favor of the prosecution.
The victim confirmed she did not know the defendant and did not permit him to enter her home. She, along with two children, identified the defendant as the assailant. The defendant was armed with a knife and screwdriver. Although no semen was recovered, the victim testified that the defendant penetrated her vaginally but withdrew before ejaculation. Forensic tests on a stain from the victim's gown indicated the defendant was the perpetrator. Witnesses for the defendant failed to provide a credible alibi; one claimed to have been with him until 10:00 p.m., while another stated he was on her couch at that time, having fallen asleep and only awakening shortly before 2:00 a.m. Given the short walking distance between the victim's and the witness's homes, the defendant had the opportunity to commit the crime and return unnoticed. The jury could reasonably reject the alibi as untrustworthy. The defendant's claims of error were found to lack merit, leading to the affirmation of his convictions and sentences. Out of 15 assigned errors, only 2 were properly briefed, and the remainder were deemed abandoned.
