## Facts

- Arthur Thompson unlawfully entered a church rectory by climbing through a window to steal money and took about $550 from a cigar box.
- As Thompson attempted to leave, the priest, Father William O’Brien, confronted and grabbed him; a struggle followed.
- Thompson threw O’Brien against a wall and repeatedly struck him; after O’Brien fell to the floor, Thompson hit him again and fled out a back door.
- O’Brien died from multiple traumatic injuries with extensive facial lacerations and blood loss.
- Medical testimony indicated the injuries were consistent with being caused by a heavy iron rod wrapped in duct tape found in Thompson’s truck; the defense argued the limited blood and absence of tissue on the rod suggested it was not used.
- Thompson was stopped and arrested for traffic violations, became a suspect after the homicide was discovered, and gave a videotaped confession.
- At trial, Thompson testified he used only his fists to break free, did not intend to kill, and believed O’Brien was still breathing when he left.

## Issues

1. Whether, viewing the evidence in the light most favorable to the prosecution, a rational juror could find beyond a reasonable doubt that Thompson committed first-degree murder arising from the killing during the church burglary.

## Decision

- The Louisiana Court of Appeal, Second Circuit, affirmed the conviction.
- The court held the evidence was sufficient under the Jackson v. Virginia standard for a rational jury to find the elements of first-degree murder beyond a reasonable doubt.
- The court deferred to the jury’s resolution of conflicts in testimony and physical evidence, including disputes about whether a weapon was used and whether Thompson intended to kill.

## Legal Principles

- On sufficiency review, the question is whether any rational trier of fact, viewing the evidence most favorably to the prosecution, could find the offense’s essential elements beyond a reasonable doubt.
- Specific intent to kill (or the required homicide mental state) may be inferred from the circumstances of the attack, including the severity and location of injuries and the use of force likely to cause death or great bodily harm.
- The jury is the primary arbiter of credibility and weight of evidence; an appellate court does not reweigh evidence or substitute its view of disputed facts if the verdict is rationally supported.
- Proof of the precise weapon used is not required if the totality of evidence supports the finding that the defendant inflicted fatal force during the charged course of conduct.

## Conclusion

The court affirmed Thompson’s first-degree murder conviction because the medical evidence, the violent nature of the assault during a burglary, and the jury’s credibility choices provided a legally sufficient basis for the verdict under the governing sufficiency-of-the-evidence standard.


State v. Thompson, 578 So. 2d 1151 (La. Ct. App. 2d Cir. 1991)