Summary
The Louisiana Fourth Circuit Court of Appeal affirmed Don C. Woods’ conviction for obstruction of justice. The court held that the evidence, including video recordings and Woods’ admission that he removed and discarded the weapon, was sufficient for a rational jury to find the requisite intent to distort a potential or future criminal investigation under Louisiana Revised Statutes § 14:130.1.
Topics
Practice areas
Questions Presented
- Whether the evidence was constitutionally sufficient to prove that Woods committed obstruction of justice by removing and discarding the weapon with the specific intent to distort the results of a potential or future criminal investigation.
Holdings
- The evidence was sufficient to support Woods's obstruction-of-justice conviction because he knowingly removed and discarded the murder weapon with the specific intent to distort the results of a potential or future criminal investigation.
Key quotations
“The defendant must also have tampered with evidence ‘with the specific intent of distorting the results’ of a criminal investigation.” (8)
“The directive that the evidence be viewed “in the light most favorable to the prosecution” requires that deference be made to the trier of fact’s rational credibility calls, evidence weighing, and inference drawing.” (9)
“The jury could reasonably determine that Defendant had the specific intent to distort the results of a “potential” “future” criminal investigation because Defendant removed and dumped the weapon immediately after the victim’s murder and did not admit to doing so until after he was arrested and questioned by the police.” (10)
Factual background
After an altercation, Woods struck the victim with a sword taken from the victim's shopping cart, causing a fatal torso wound. Video evidence showed Woods leaving the scene with the sword, and Woods later admitted that he discarded it after driving away. The jury could infer that Woods removed and concealed the weapon intending to distort a potential or future criminal investigation.
Procedural history
A grand jury indicted Woods for second degree murder and obstruction of justice. The jury convicted him of obstruction of justice but could not reach a verdict on the murder charge, resulting in a mistrial on that count. Woods later pleaded guilty to amended manslaughter and received concurrent ten-year sentences for manslaughter and obstruction of justice. He appealed only the obstruction-of-justice conviction, arguing that the evidence failed to establish specific intent.