State v. Hogan
2000 La. App. LEXIS 303, 753 So.2d 965, 2000 WL 230226 (2000)
Premium Feature
Subscribe to Lexplug to listen to the Case Podcast.
Rule of Law:
The credible and uncontradicted testimony of a single witness, if believed by the trier of fact, is legally sufficient evidence to support a finding that the essential elements of a crime have been proven beyond a reasonable doubt.
Facts:
- On November 22, 1997, Berma James Hogan knocked on the door of an elderly man who recognized Hogan as a friend of his grandson.
- Hogan asked for a cigarette, and when the victim cracked the door open, Hogan pushed it fully open and attacked the victim.
- Hogan forced his way into the victim's home without permission.
- Inside the house, Hogan grabbed the victim by the throat, threw him to the floor, and held him down.
- Hogan then removed money from the victim's pockets and fled the scene, leaving the victim on the floor.
Procedural Posture:
- Berma James Hogan was charged by the district attorney with aggravated burglary in a Louisiana trial court.
- Following a trial, a unanimous jury convicted Hogan as charged.
- The state then filed a habitual offender bill, and the court adjudged Hogan a second felony habitual offender.
- The trial court sentenced Hogan to 20 years at hard labor.
- Hogan, as appellant, appealed his conviction to the Court of Appeal of Louisiana, Second Circuit (an intermediate appellate court), against the State of Louisiana, as appellee.
Premium Content
Subscribe to Lexplug to view the complete brief
You're viewing a preview with Rule of Law, Facts, and Procedural Posture
Issue:
Is a single victim's credible testimony sufficient evidence for a rational jury to find all elements of aggravated burglary proven beyond a reasonable doubt, specifically the element of unauthorized entry?
Opinions:
Majority - Gaskins, J.
Yes. A single victim's credible testimony is sufficient evidence for a rational jury to find all elements of a crime proven beyond a reasonable doubt. Applying the standard from Jackson v. Virginia, an appellate court must view the evidence in the light most favorable to the prosecution. The victim's testimony clearly established that Hogan made an unauthorized entry into his home, intended to commit a theft, and committed a battery upon him inside the residence. A reviewing court accords great deference to a jury’s credibility determinations, and in the absence of internal contradiction or irreconcilable conflict with physical evidence, one witness's testimony is sufficient to support a conviction.
Analysis:
This decision reinforces the high degree of deference appellate courts must give to a jury's findings of fact, particularly regarding witness credibility. It solidifies the principle that under the Jackson v. Virginia standard, the testimony of a single, credible witness can be legally sufficient to sustain a conviction for a serious felony. This makes it exceedingly difficult for a defendant to succeed on a sufficiency of the evidence appeal by merely challenging the victim's account without presenting contradictory evidence, underscoring the jury's role as the ultimate arbiter of truth.
