State of Louisiana v. Eric Dale Mickelson

Summary

The Supreme Court of Louisiana reversed Eric Dale Mickelson’s first-degree murder conviction and death sentence and remanded for a new trial. The court found the evidence sufficient to support specific intent but held that the district court erred in denying a challenge for cause to a prospective juror, requiring reversal under Louisiana law.

Holdings

1. The evidence was sufficient for a rational trier of fact to find that Mickelson had the specific intent to kill or inflict great bodily harm, notwithstanding evidence that he was intoxicated.
2. A prospective juror must be excused for cause when the juror's responses establish an inability or unwillingness to follow the law requiring consideration of relevant mitigating circumstances, and the juror is not rehabilitated.
3. When the district court erroneously denies a defendant's challenge for cause, the defendant uses a peremptory challenge to remove the juror, and the defendant exhausts all available peremptory challenges, prejudice is presumed and reversal is automatic.
4. The capital-sentencing statute permits the sentencing hearing to focus on the character and propensities of the victim, and the district court erred in excluding testimony about the victim's character and propensities.

Questions Presented

1. Whether the evidence was sufficient for a rational factfinder to find beyond a reasonable doubt that Mickelson possessed the specific intent required for first-degree murder despite evidence of cocaine intoxication.
2. Whether the district court erred in denying Mickelson's challenge for cause to prospective juror Roy Johnson, where Johnson repeatedly stated that he would not consider intoxication as a mitigating circumstance in capital sentencing and Mickelson exhausted his peremptory challenges.
3. Whether the district court's denial of the challenge for cause required reversal of the conviction and death sentence.

Disposition

reversed_and_remanded