## Facts

- Gollia McGee was found dead in her home after being beaten with a hammer and stabbed with a knife.
- New Orleans police investigated and took multiple statements from McGee’s grandson, Edward Badon.
- Badon initially claimed that two men wearing Sewerage and Water Board uniforms entered the home and attacked both him and McGee.
- Officers determined that Badon’s initial account was false. After his arrest, Badon gave two additional false versions of events.
- Badon ultimately admitted to homicide investigator Byron Adams that he killed McGee because she would not let him use her vehicle.
- During a search of McGee’s home in connection with the homicide investigation, Adams seized (among other items) a bloodstained denim jacket found in Badon’s room and a machete found next to McGee’s bed.
- At trial, Badon objected to admission of the jacket and machete, arguing there was no proof the blood on the jacket came from Badon or McGee and no proof the machete was used in the killing; he also argued the items were unfairly prejudicial.
- The trial court admitted the evidence, the jury convicted Badon of second-degree murder, and Badon appealed.

## Issues

1. Did the trial court abuse its discretion by admitting a bloodstained denim jacket and a machete where the State did not conclusively prove the source of the blood or that the machete was used as a murder weapon?
2. Were the jacket and machete excludable because any probative value was substantially outweighed by the danger of unfair prejudice under Louisiana Code of Evidence art. 403?

## Decision

- The Louisiana Court of Appeal, Fourth Circuit affirmed Badon’s conviction.
- The court held the trial court did not abuse its discretion in finding the bloodstained jacket and machete relevant to the case.
- The court further held that the trial court acted within its discretion in concluding the items’ probative value was not substantially outweighed by unfair prejudice.

## Legal Principles

- Under La. Code Evid. art. 401, evidence is relevant if it has any tendency to make a fact of consequence more or less probable than it would be without the evidence.
- Under La. Code Evid. art. 402, relevant evidence is generally admissible; irrelevant evidence is inadmissible.
- Under La. Code Evid. art. 403, relevant evidence may be excluded if its probative value is substantially outweighed by the danger of unfair prejudice (or other listed risks such as confusion or misleading the jury).
- A trial court has broad discretion in evidentiary rulings on relevance and art. 403 balancing, and an appellate court reviews those rulings for abuse of discretion.
- The absence of a conclusive scientific or direct link between an item and the charged offense typically affects the weight the jury may give the evidence, not whether the evidence is admissible, so long as the item has a logical connection to the facts in dispute.

## Conclusion

The Fourth Circuit affirmed Badon’s second-degree murder conviction, holding that the bloodstained denim jacket found in his room and the machete found beside the victim’s bed were properly admitted because they met Louisiana’s low threshold for relevance and the trial court did not err in concluding the danger of unfair prejudice did not substantially outweigh their probative value.


State v. Badon, 664 So. 2d 1291 (1995)