Background
Stefan Briggs and his brother, Donald, were convicted by a jury of the second-degree murder of Jazaylon Levy, who was shot and killed in Abbeville, Louisiana, in July 2022. Both brothers were sentenced to mandatory life imprisonment at hard labor without the benefit of parole, probation, or suspension of sentence. The Briggs brothers appealed their convictions to the Louisiana Court of Appeal, Third Circuit.
In an initial decision, the court of appeal reversed the convictions, finding that the purely circumstantial evidence presented by the prosecution was insufficient to prove guilt beyond a reasonable doubt. The State of Louisiana then appealed that ruling to the Louisiana Supreme Court. The Supreme Court reversed the appellate court, holding that the court had improperly substituted its own judgment for the jury’s verdict. The Supreme Court reinstated the convictions and sentences and remanded the case back to the court of appeal to address other legal assignments of error that it had not reached in its first decision.
The Court’s Holding
On remand, the court affirmed Stefan Briggs’s conviction and sentence, rejecting his two remaining arguments. First, Briggs argued that the trial court should have granted his motion for a new trial because one of the jurors, Laura Mouton, failed to disclose during jury selection (voir dire) that she was related to the victim’s family. The court found this argument lacked merit. At a hearing, the juror testified she did not know the victim and was unaware of her distant relationship to the victim’s paternal aunt—her fifth or sixth cousin—until after the trial was over. The trial court found her testimony credible and that the relationship was “tenuous at best.” The appellate court agreed, concluding Briggs had failed to show the juror was biased or had intentionally concealed information.
Second, Briggs argued the trial court erred by allowing the prosecutor to introduce evidence of uncharged other crimes, namely testimony about ongoing gun violence between groups associated with the Briggs brothers and their rivals. The court, looking at the identical issue raised by the co-defendant in the consolidated case, held that this issue was not properly preserved for appeal. During the trial, defense counsel objected to the testimony only on the grounds of “relevance” and did not state the specific objection that it was inadmissible “other crimes evidence.” Because a specific objection was not made on the record, the appellate court ruled the issue was waived and could not be reviewed.
Key Takeaways
- A conviction will not be overturned for alleged juror misconduct unless the defendant proves that the juror was actually biased or intentionally lied during jury selection; a distant, unknown family connection between a juror and a victim’s relative is insufficient to prove bias.
- To preserve a legal issue for appeal, trial counsel must make a timely and specific objection on the record. A general objection, such as for “relevance,” is not sufficient to preserve an appeal on more specific grounds like the improper admission of “other crimes” evidence.
- Appellate courts will not speculate about what occurred during an unrecorded bench conference and will only review errors patent on the face of the official court record.
Why It Matters
This opinion reinforces the high bar for challenging a jury verdict based on post-trial discoveries about a juror’s background. It emphasizes that defendants must show actual prejudice, not just a speculative potential for it, to be granted a new trial. The decision also serves as a critical reminder for trial lawyers that procedural rules, particularly the requirement for specific and timely objections, are strictly enforced. A failure to state the precise legal grounds for an objection in the heat of trial can result in an appellate court refusing to consider an otherwise valid legal argument, effectively preventing a defendant from having the issue reviewed.