Background
A jury convicted Brandon Wayne Lindsey of the second-degree murder of his girlfriend, Heaven Weed, and the trial court sentenced him to life imprisonment. Hours before Weed suffered her fatal injuries, security staff removed the couple from a Shreveport bar because their conflict was becoming physical. The following day, Weed’s mother found her unconscious in bed with a swollen face and blood coming from her mouth. Weed was declared brain-dead eight days later. The coroner classified her death as a homicide caused by closed-head trauma resulting in a brain hemorrhage. She also had two broken ribs, bruises throughout her body, and what appeared to be an abrasion on her neck from a garrote.
Investigators found blood spatter throughout the house, an odor of bleach, bloody clothing, and items bearing Weed’s blood near or inside the washing machine. Weed’s blood was on Lindsey’s clothes, and his DNA was mixed with her blood on one shirt. His hands were swollen and bruised, location records placed his truck and cellphone at Weed’s house during the relevant period, and those records contradicted his accounts to police.
Over Lindsey’s objection, the prosecution introduced testimony from former girlfriend Haley Hudson under Louisiana Code of Evidence article 412.4. Hudson described repeated, severe domestic beatings during their relationship. Lindsey argued on appeal that article 404(B)’s general prohibition against propensity evidence still applied and that, in any event, article 403 required exclusion because the testimony’s unfair prejudice substantially outweighed its probative value.
The Court’s Holding
The Second Circuit affirmed Lindsey’s conviction and sentence. It held that article 412.4 creates an exception to article 404(B)’s general prohibition against using other acts to show character and conduct in conformity with that character. In prosecutions involving abusive behavior against a household member or dating partner, qualifying evidence of other assaultive conduct may be considered for any relevant purpose, including propensity, subject to article 403 balancing.
The court further held that the trial court did not abuse its discretion by admitting Hudson’s testimony. Viewed alongside the substantial circumstantial evidence connecting Lindsey to Weed’s killing, the prior violence had extremely high probative value because it showed a longstanding pattern of severe, unarmed violence against dating partners. The testimony was inflammatory, but it concerned similar conduct, rested on Hudson’s direct personal experience, and was substantially corroborated by Lindsey’s guilty pleas to multiple crimes against her. Those considerations mitigated the risk of unreliable or unsubstantiated allegations, and the danger of unfair prejudice did not substantially outweigh the evidence’s probative value.
Key Takeaways
- Louisiana Code of Evidence article 412.4 permits qualifying domestic-abuse evidence to be used for propensity purposes despite article 404(B)’s general rule, but it does not create a presumption of admissibility.
- Courts must still apply article 403 and exclude the evidence when its probative value is substantially outweighed by unfair prejudice or the other dangers listed in that provision.
- Similarity to the charged offense, direct firsthand testimony, prior convictions corroborating the allegations, and the strength of the remaining evidence supported admission here.
Why It Matters
The decision confirms that Louisiana’s domestic-violence evidence rule is a substantive exception to the ordinary bar on propensity evidence. Prosecutors may use qualifying prior assaultive conduct to show a defendant’s propensity for domestic violence, while trial courts retain discretion to exclude evidence that fails article 403’s balancing test.
The opinion also illustrates how corroboration and context affect that balance. Even highly emotional testimony may be admitted when it is reliable, similar to the charged conduct, and materially strengthens an otherwise substantial body of case-specific evidence.