State v. Stockstill, 2018 KA 1586
| Decision Date | 03 July 2019 |
| Docket Number | 2018 KA 1586 |
| Parties | STATE OF LOUISIANA v. MARGARET CAMAILLE STOCKSTILL |
| Court | Court of Appeal of Louisiana — District of US |
NOT DESIGNATED FOR PUBLICATION
On Appeal from the Twenty-Second Judicial District Court In and for the Parish of St. Tammany State of Louisiana
No. 589076 Div. "D"
The defendant, Margaret Camaille Stockstill, was charged by grand jury indictment with second degree murder, a violation of La. R.S. 14:30.1. She pled not guilty. After a trial by jury, she was found guilty as charged. The trial court denied the defendant's motion for new trial and motion for post-verdict judgment of acquittal. She was sentenced to life imprisonment at hard labor without the benefit of probation, parole, or suspension of sentence. The defendant now appeals, assigning error to the sufficiency of the evidence, the alleged violation of her right of confrontation, and to the admission of testimony on the victim's state of mind. For the following reasons, we affirm the conviction and sentence.
On April 14, 2017, after 10:00 p.m., officers of the St. Tammany Parish Sheriff's Office (STPSO) responded to the scene of a shooting at a residence located in Folsom. One of the residents, Kristin Copeland, witnessed the defendant, her longtime friend, shoot Cody Couch (Couch), Copeland's fiancé.1 According to Copeland, the defendant arrived at her home that day while Couch was still at work. When Couch arrived home, they agreed to "hang out and play cards and drink a little bit," so the defendant allowed Couch to borrow her vehicle to go purchase playing cards and alcoholic beverages. After Couch returned with the items, Copeland became upset because Couch wanted to go to a bar with his friends instead of staying home with Copeland and the defendant. Despite Copeland's pleas for him to stay home, Couch left to go to the bar.
While Couch was gone, Copeland consumed alcohol, complained to the defendant about Couch's conduct, and repeatedly attempted to contact Couch. Copeland became even more irate, as she could hear music in the backgroundwhenever Couch would answer her calls. Copeland went out to her storage shed, set some clothing on fire, and told him during one of their phone calls that she had set his belongings on fire.2 Copeland also told Couch that he could not stay at the house that night, instructing him to stay at his mother's house. She packed a bag of Couch's belongings, placed it on the porch, and locked the front door.
Later, when Couch arrived home, he began banging on the front door, which was still locked. Copeland attempted to lock the back door, but when she got to the kitchen, Couch was already inside. Copeland told Couch to leave but he refused. Copeland pushed Couch towards the living room. He stumbled, as he too had been drinking that night. Eventually, they all ended up in the living room, as the altercation intensified and became physical.3 The defendant ultimately retrieved her gun from her purse and fired at Couch, shooting him in the abdomen. Copeland dialed 911 and attempted to assist Couch, as the defendant went outside to talk to the 911 dispatcher.4 Couch died from the single gunshot to the abdomen.
The day after the shooting, the police conducted interviews of Copeland and the defendant, and the defendant was re-interviewed days later. During her police interview, Copeland indicated that Couch refused to leave, and that the altercationinvolved yelling and shoving, which led the defendant to pull her gun out of her purse. In Copeland's estimation, Couch was standing about one foot away from the defendant when the defendant fired the gun, striking Couch. Copeland denied that Couch ever threatened to kill anyone, punched or hit her, advanced towards the defendant, or reached for the gun before it was fired.5
After being advised of her Miranda6 rights at the time of both interviews, the defendant maintained that she was protecting herself, Copeland, and the infant present at the time of the shooting. The defendant described a string of violent acts by Couch, contending that he slammed Copeland down on the coffee table, tried to set the sofa on fire while the defendant was sitting on it, repeatedly struck Copeland and the defendant, threatened to kill them several times, and had an object7 in his hand when the defendant pulled the gun out. The defendant further claimed that Couch was five or six feet away from her when she pulled the gun out. According to the defendant, Couch repeatedly dared her to shoot him as he walked towards her, grabbed her throat, grabbed the barrel of the gun, and pressed the gun against his stomach just before she shot him.
At trial, Copeland again described the physical aspect of the altercation as pushing and shoving among the three individuals. She indicated that Couch did not verbally threaten her or the defendant or arm himself with a knife on the nightin question. She consistently denied that Couch ever hit her or the defendant, or advanced towards the defendant before the defendant shot him.
In combined arguments on assignments of error numbers one, two, and three, the defendant challenges the sufficiency of the evidence. In assignment of error number one, the defendant argues that the State failed to prove that she did not act in self-defense or in defense of another. As the defendant concedes, "[her] perceptions regarding the intensity of the fight--both in terms of duration and in terms of force used--may have been more extreme than the pictures would bear out." However, she contends that photographs did support her description of the fight that took place in the infant's room. She further contends that she did not know Couch well, that she had no way of knowing what he was capable of doing, and that she feared that he would use deadly force upon her and Copeland. Claiming that Couch picked up a spackling knife at one point, the defendant contends that Copeland downplayed the fight and the volatile nature of her relationship with Couch. She contends that she was justified in using deadly force to protect herself and Copeland from further attack.
In assignment of error number two, the defendant alternatively argues that the evidence, at best, supported a verdict of manslaughter. She relies on the above account of the incident, her claim that Couch was in an enraged and drunken condition when she shot him, and her contention that Copeland's infant was endangered during the incident. The defendant argues that the killing was committed in sudden passion and heat of blood, involving provocation by Couch sufficient to deprive the average person of his or her cool thought and calm reflection. The defendant concludes, viewing the evidence in the light most favorable to the prosecution, the jury could not have reasonably found that the mitigatory factors were not established by a preponderance of the evidence.
The defendant also argues that Copeland was not in a position to describe the defendant's perception of the physical altercation or Couch's intentions, and that Copeland's account of the incident was illogical, internally inconsistent, and inconsistent with the physical findings and audio recording. In arguing that Copeland could not recall the night's events with any degree of accuracy, the defendant notes that Copeland admitted that she was consuming alcohol that night. Thus, the defendant contends (in assignment of error number three) that the trial court erred in denying her motion for postverdict judgment of acquittal.
The standard of review for the sufficiency of the evidence to uphold a conviction is whether, 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. Jackson v. Virginia, 443 U.S. 307, 319, 99 S.Ct. 2781, 2789, 61 L.Ed.2d 560, 573 (1979). See also La. C.Cr.P. art. 821(B); State v. Ordodi, 2006-0207 (La. 11/29/06), 946 So.2d 654, 660; State v. Jackson, 2018-0261 (La. App. 1 Cir. 11/2/18), 265 So.3d 928, 933, writ denied, 2018-1969 (La. 4/22/19), 268 So.3d 304. The Jackson standard of review, incorporated in article 821, is an objective standard for testing the overall evidence, both direct and circumstantial, for reasonable doubt. See State v. Dyson, 2016-1571 (La. App. 1 Cir. 6/2/17), 222 So.3d 220, 228, writ denied, 2017-1399 (La. 6/15/18), 257 So.3d 685.
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. See State v. Patorno, 2001-2585 (La. App. 1 Cir. 6/21/02), 822 So.2d 141, 144. When a case involves circumstantial evidence and the trier of fact reasonably rejects the hypothesis of innocence presented by the defense, that hypothesis falls, and the defendant is guilty unless there is anotherhypothesis which raises a reasonable doubt. State v. Dyson, 222 So.3d at 228; State v. Morris, 2009-0422 (La. App. 1 Cir. 9/11/09), 22 So.3d 1002, 1011.
Second degree murder is the killing of a human being when the offender has a specific intent to kill or to inflict great bodily harm. La. R.S. 14:30.1(A)(1). Specific criminal 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). Though intent is a question of fact, it need not be proven as a fact. It may be inferred from the circumstances of the transaction. Specific intent may be proven by direct evidence,...
To continue reading
Request your trial