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Law School Case Brief

State v. Thompson - 578 So. 2d 1151 (La. Ct. App. 1991)

Rule:

Pursuant to La. Code Crim. Proc. Ann. art. 821, the standard of review for the sufficiency of the evidence to uphold a conviction is whether or not, viewing the evidence in the light most favorable to the prosecution, a rational trier of fact could conclude that the State proved the essential elements of the crime beyond a reasonable doubt.

Facts:

On Jan. 8, 1989, defendant Arthur Thompson climbed through a window and entered the rectory of a church where he found a cigar box containing approximately $ 550 cash in a desk drawer. He placed this box under his arm and attempted to leave when he was confronted by the victim, Father William O'Brien. A struggle ensued; Thompson threw Fr. O'Brien against the wall and beat him with his right fist, even after Fr. O'Brien fell to the floor. Fr. O'Brien bled to death. Police officers later obtained Thompson's videotaped confession to the murder. At trial in Louisiana state court, the coroner testified that Fr. O'Brien's injuries were consistent with the use of an iron bar recovered from Thompson's car. Thompson testified that he did not use the iron bar, but rather hit Fr. O'Brien with his fists; that he did not intend to kill Fr. O'Brien; and that Fr. O'Brien was still breathing when he fled the church. A jury found Thompson guilty of first-degree murder, and Thompson was sentenced to life imprisonment at hard labor without benefit of parole, probation, or suspension of sentence. Thompson appealed.

Issue:

Was there sufficient evidence to support Thompson's conviction for first-degree murder?

Answer:

Yes.

Conclusion:

The appellate court affirmed Thompson's conviction. The court held that Thompson's statement in his confession—that he struck Fr. O'Brien after Fr. O'Brien fell to the floor, causing Fr. O'Brien to suffer severe injuries from which he died—was sufficient evidence to show that Thompson had the intent to inflict great bodily harm on Fr. O'Brien.

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