Background
On April 25, 2021, Devonta Ennis was driving on Prescott Road in Baton Rouge when two vehicles — a white Chevrolet Traverse and a silver Nissan Armada — boxed in his car at an intersection. An occupant of the Traverse exited and shot Ennis multiple times, killing him. Surveillance footage from a nearby Dollar General captured the encounter, though the video was too grainy to clearly identify the shooter. Both vehicles were found that evening in a remote park, deliberately set on fire. Each had been reported stolen on the night of the murder and were registered to or leased by women who were romantically involved with defendant Curtis Lee Stewart, Jr. and with whom he had fathered children.
Stewart was indicted for second-degree murder. He waived a jury and proceeded to a bench trial. The State’s case was built entirely on circumstantial evidence: cell phone geolocation records placing Stewart’s phone in the area of the vehicle theft and the murder scene around the time of both events; testimony from Shalana Sims (owner of the Traverse) that Stewart had taken her car and later told her to “leave it alone”; jailhouse calls in which Stewart appeared to coordinate payments to secure the silence of Sims and Tierra Hayes (lessee of the Armada); and Stewart’s own conduct during a police interview, in which he denied knowing the victim but then referred to him by his nickname, and provided investigators a false phone number. The trial court found Stewart guilty and sentenced him to life imprisonment without parole.
The First Circuit Court of Appeal reversed the conviction by a two-to-one vote, finding the evidence insufficient to establish Stewart’s identity as the perpetrator. The majority concluded that without physical evidence or a witness identification placing Stewart in one of the vehicles, the trial court could only speculate that he was the shooter. The State sought review, and the Louisiana Supreme Court granted certiorari.
The Court’s Holding
The Louisiana Supreme Court reversed the First Circuit and reinstated Stewart’s conviction and life sentence. Writing for the majority, Justice McCallum held that the court of appeal applied the wrong legal framework by demanding proof that Stewart was the actual shooter. Under Louisiana’s principal liability statute, La. R.S. 14:24, all persons “concerned in the commission of a crime” — whether they directly commit the act, aid and abet, or procure another to commit it — are treated as principals and may be convicted of the offense itself. The State need not explicitly charge or argue principal liability; the indictment for the underlying offense is sufficient.
Applying the Jackson v. Virginia, 443 U.S. 307 (1979), standard — whether, viewing the evidence in the light most favorable to the prosecution, any rational trier of fact could have found the essential elements of the crime beyond a reasonable doubt — the Court found the evidence more than adequate. The cell phone records showed Stewart’s device moving from the vicinity of Sims’s home (where the Traverse was taken) to the Prescott Road murder scene and remaining largely stationary during the brief window of the shooting, before departing. Sims identified Stewart as the person who took her vehicle, and Stewart’s instruction to her to ask no questions was evidence of consciousness of guilt. Jailhouse calls demonstrated that Stewart attempted to procure the unavailability of two key witnesses. His false denial of knowing the victim — contradicted by his own use of the victim’s nickname — further supported an inference of a guilty mind. Relying on its recent decision in State v. Briggs, 25-00529 (La. 5/1/26), the Court reaffirmed that principal liability attaches even when a defendant’s precise role is uncertain, so long as knowing participation and specific intent are established.
The Court acknowledged the absence of DNA or physical evidence directly tying Stewart to the shooting, but emphasized that the appellate court’s role is not to substitute its view of the facts for the trier of fact’s. The trial court, as finder of fact, properly weighed the circumstantial evidence under La. R.S. 15:438 and concluded it excluded every reasonable hypothesis of innocence. The First Circuit’s reversal was an improper encroachment on that factfinding function.
Key Takeaways
- Louisiana’s principal liability statute (La. R.S. 14:24) does not require the State to prove a defendant fired the fatal shot; conviction for second-degree murder is proper if the evidence shows knowing participation in the crime, regardless of precise role.
- The State need not explicitly charge or argue principal liability — an indictment for the underlying offense is sufficient, and a court may convict as a principal even when the prosecution’s closing argument focused on the defendant as the direct perpetrator.
- Under Jackson v. Virginia, an appellate court may not reverse a conviction merely because the evidence is circumstantial or because direct physical identification is absent; the question is only whether a rational trier of fact could find guilt beyond a reasonable doubt when the evidence is viewed in the prosecution’s favor.
- Consciousness-of-guilt inferences are proper from a defendant’s witness intimidation efforts, evasive post-arrest statements, lies later contradicted by the defendant’s own words, and deliberate concealment of communications devices.
Why It Matters
This decision reaffirms — and sharpens — Louisiana’s broad principal liability doctrine in the context of sufficiency-of-evidence review. Defense counsel and prosecutors alike should note that appellate courts in Louisiana are not permitted to demand an evidentiary link to the defendant as the specific actor who pulled the trigger; participation in a coordinated killing, supported by circumstantial evidence, is constitutionally sufficient. The ruling aligns with the Court’s nearly simultaneous decision in Briggs and signals a consistent posture against intermediate appellate courts substituting their factual judgments for those of trial courts.
For practitioners, the case is also a notable illustration of the evidentiary weight Louisiana courts assign to cell phone geolocation data, jailhouse calls, and forfeiture-by-wrongdoing findings. Stewart’s own conduct — silencing witnesses from jail, lying to investigators, and providing a false phone number — supplied the consciousness-of-guilt evidence that ultimately proved decisive in sustaining the bench trial verdict.