## Facts

- Police found the nude, decomposing body of a man in his bedroom; he had a single stab wound to the upper chest/neck area.
- Brenda Rodrigue voluntarily gave police a statement describing an argument, forced confinement, beating, and sexual assault by the victim, culminating in her stabbing him once with a knife taken from a dresser.
- Rodrigue led police to where she had hidden the knife after leaving the scene.
- The State charged Rodrigue with second-degree murder.
- At trial, Rodrigue asserted justification/self-defense based on the victim’s alleged violence and abuse.
- The State presented testimony from the victim’s sister that the couple appeared affectionate (“arm-in-arm”) shortly before the homicide and showed no signs of fighting.
- Defense cross-examination sought to elicit evidence bearing on the victim’s dangerous character (including questions about drinking and related conduct), but the trial court sustained objections and excluded broader evidence of the victim’s dangerous character and the prior abusive nature of the relationship.
- The jury convicted Rodrigue; the court of appeal affirmed.

## Issues

1. Whether excluding evidence of the victim’s dangerous character and prior abuse, offered to support justification/self-defense, violated the defendant’s right to present a defense under La. Const. art. I, § 16.
2. Whether La. Code Evid. art. 404(A)(2)’s domestic-violence character-evidence exception applies when the parties had separated shortly before the homicide.

## Decision

- The Louisiana Supreme Court reversed the conviction and remanded for a new trial.
- The court held the trial court erred by excluding evidence of the victim’s dangerous character and the prior abusive relationship context.
- The court concluded the exclusion unduly restricted Rodrigue’s constitutional right to present a defense because the evidence was central to the justification/self-defense theory and was not harmless in light of the State’s portrayal of the relationship.

## Legal Principles

- La. Const. art. I, § 16 protects a criminal defendant’s right to present a defense; evidentiary limits cannot be applied rigidly when they bar material defense evidence.
- In homicide cases asserting justification/self-defense, evidence of the victim’s dangerous character may be relevant to the defendant’s perception of danger and the reasonableness of the defensive force.
- La. Code Evid. art. 404(A)(2) permits, in domestic-violence-related prosecutions, admission of evidence of the victim’s dangerous character; application focuses on whether the offense arises from a domestic-violence situation rather than a formal requirement that the parties still be cohabiting at the moment of the offense.
- Excluding victim-character and relationship-abuse evidence that corroborates the defendant’s account and rebuts the State’s depiction of a peaceful relationship can constitute reversible error when it substantially impairs evaluation of the justification claim.

## Conclusion

The Louisiana Supreme Court ordered a new trial after finding that the trial court’s exclusion of evidence about the victim’s dangerous character and the parties’ abusive history improperly limited the defendant’s ability to present a justification/self-defense case, in violation of La. Const. art. I, § 16 and the purpose of La. Code Evid. art. 404(A)(2).


State v. Rodrigue, 734 So. 2d 608 (La. 1999)