## Facts

- Connie Guidry Gaudet disappeared on February 18, 1984, after returning home in Lockport, Louisiana, where she lived with her husband, Dale Gaudet, and their two young children.
- Dale claimed he last saw Connie around midnight and that she called the next morning saying she left with a friend.
- Connie’s mother received a letter purportedly from Connie stating she left with another man and praising Dale; forensic testing determined Connie did not write it, and the letter was postmarked locally.
- Over time, Dale told others Connie contacted him after the disappearance and that he visited her, but no one else verified any post-disappearance contact.
- In 1985, Dale obtained a divorce from Connie and later remarried; he continued living in the same house for a period and later sold it.
- In 1991, new owners discovered skeletal remains buried in the yard, wrapped in a mattress cover; the remains were identified as Connie’s.
- Dale was indicted for second-degree murder, convicted by a jury, and sentenced to life imprisonment at hard labor without benefit of probation, parole, or suspension of sentence.

## Issues

1. Whether alleged discovery deficiencies by the State warranted reversal or a new trial based on prejudice.
2. Whether the trial court properly excluded defense-offered voice-stress test results.
3. Whether testimony by Dale’s second wife about his statements and conduct was barred as confidential spousal communications.
4. Whether the chain of custody for the skeletal remains and related evidence was sufficient for admissibility.
5. Whether the circumstantial evidence was sufficient to support second-degree murder under Jackson v. Virginia and Louisiana’s circumstantial-evidence standard.
6. Whether denial of the motion for new trial was error.

## Decision

- The Louisiana First Circuit affirmed the conviction and sentence.
- The court found no reversible discovery error because the defendant failed to show prejudice to substantial rights.
- The court upheld exclusion of voice-stress evidence as unreliable, polygraph-like proof not accepted for admissibility.
- The court held spousal privilege did not bar the second wife’s testimony because the statements were not intended as confidential marital communications to her.
- The court held the chain of custody was adequate for admissibility; any minor gaps affected weight, not admissibility, absent a showing of likely alteration or misidentification.
- The court found the circumstantial evidence sufficient for a rational jury to find guilt beyond a reasonable doubt and to reject reasonable hypotheses of innocence.
- The court affirmed denial of a new trial because the asserted errors, individually or cumulatively, did not warrant relief.

## Legal Principles

- Discovery-related relief requires a showing that nondisclosure or deficiency prejudiced the defendant’s substantial rights.
- Polygraph-type techniques, including voice-stress testing, may be excluded as insufficiently reliable for admission.
- Spousal privilege protects only confidential communications between spouses intended as private marital disclosures; statements not directed to the spouse as such (including statements aimed at a third person and merely overheard) are not privileged.
- Chain of custody requires a showing of reasonable assurance of identity; alleged breaks typically go to evidentiary weight unless there is a concrete showing of alteration or misidentification.
- In circumstantial cases, sufficiency review applies Jackson v. Virginia; Louisiana also requires that the evidence exclude every reasonable hypothesis of innocence, assessed in the light most favorable to the prosecution.

## Conclusion

The court affirmed Gaudet’s second-degree murder conviction and life sentence, holding that the trial court committed no reversible error in discovery and evidentiary rulings, that spousal privilege did not bar the challenged testimony, and that the circumstantial evidence—including the fabricated letter, inconsistent accounts, incriminating conduct, and discovery of the victim’s remains at the former marital home—was legally sufficient to sustain the verdict.


State v. Gaudet, 638 So. 2d 1216 (La. Ct. App. 1st Cir. 1994)