## Facts

- Carolee Crowder separated from her husband and lived with Randy Brown.
- On April 23, 1979, Carolee, Randy, and Randy’s brother Robert Brown (defendant) argued, and the conflict turned violent.
- Randy and Robert slapped and punched Carolee during the altercation.
- Robert then shot Carolee in the head.
- Carolee lost consciousness and later remembered being taken to a hospital emergency room a few hours after the shooting.
- At the hospital, Carolee learned she had a bullet wound in her forehead; the bullet penetrated her skull and entered her brain.
- Carolee survived, but the shooting left her partially paralyzed.
- The State charged Robert by bill of information with aggravated battery under La. R.S. 14:34.
- At trial, the court allowed Nurse Lois Taylor to testify about what Carolee said in the emergency room.
- Taylor testified she asked Carolee, “Can you tell me what happened to you?” and Carolee responded, “Randy beat me and Randy’s brother, Robert, shot me.”
- The jury found Robert guilty as charged, and the trial court sentenced him to ten years at hard labor.
- Robert appealed, challenging, among other things, the admission of the nurse’s testimony and the sufficiency of the evidence.

## Issues

1. Whether the trial court erred by admitting, through the emergency-room nurse, the victim’s out-of-court statement identifying Robert Brown as the shooter as an exception to the hearsay rule (res gestae/spontaneous statement).
2. Whether the evidence, viewed in the light most favorable to the prosecution, was sufficient for a rational jury to find beyond a reasonable doubt that Robert committed aggravated battery, including proof of identity.
3. Whether any of the remaining assignments of error required reversal of the conviction or sentence.

## Decision

- The Louisiana Supreme Court affirmed Robert Brown’s conviction and ten-year hard-labor sentence for aggravated battery.
- The court held the victim’s emergency-room statement to Nurse Taylor (“Randy beat me and Randy’s brother, Robert, shot me”) was properly admitted under Louisiana’s res gestae/spontaneous-statement doctrine.
- The court held the evidence was sufficient under Jackson v. Virginia for a rational trier of fact to find Robert guilty beyond a reasonable doubt.
- The court rejected the remaining assignments of error and found no reversible error.

## Legal Principles

- Under Louisiana law as applied in this case, a statement closely connected to a startling event and made while the declarant remains under the stress of that event may be admitted as part of the res gestae (spontaneous statement), even though it is hearsay.
- A victim’s statement to medical personnel shortly after a serious injury, while receiving emergency care and still affected by the event, may qualify as a spontaneous statement when the circumstances support trustworthiness.
- Aggravated battery under La. R.S. 14:34 requires proof of a battery committed with a dangerous weapon.
- On appellate review of sufficiency of the evidence, the question is whether, viewing the evidence in the light most favorable to the prosecution, any rational juror could find the essential elements proved beyond a reasonable doubt (Jackson v. Virginia).
- Admission of evidence and related trial rulings are generally reviewed for abuse of discretion; reversal is not warranted absent prejudicial error affecting the verdict.

## Conclusion

State v. Brown upheld an aggravated-battery conviction where the victim survived a gunshot wound but suffered lasting paralysis; the Louisiana Supreme Court ruled that the victim’s emergency-room identification of “Randy’s brother, Robert” as the shooter was admissible as a spontaneous statement under the res gestae doctrine and that the trial evidence was sufficient for a rational jury to find Robert Brown guilty beyond a reasonable doubt.


State v. Brown, 395 So. 2d 1301 (1981)