State v. Griffin

Pamela Griffin (defendant) went to the woods with Gary Braggs in Braggs’s truck to smoke crack cocaine and have sex. Griffin later asked Braggs to meet her behind the truck to investigate a noise. Griffin then shot Braggs twice in the head with a gun she found in the truck, jumped in the truck, and drove away. Griffin drove the truck into a tree and into a ditch. Griffin then left the truck and began walking down the road. Craig Harris approached Griffin in a truck and asked whether Griffin needed help. Griffin forced Harris out of the truck at gunpoint and then shot Harris in the head. Griffin then stole Harris’s truck and drove away. Harris died from the gunshot wound, and the State of Louisiana (plaintiff) charged Griffin with first-degree murder. Griffin claimed that she did not have the requisite specific intent to commit first-degree murder because she was intoxicated from smoking crack. Before trial, the prosecution gave notice under State v. Prieur, 277 So. 2d 126 (La. 1973), of its intent to introduce evidence of Griffin’s other crimes at trial. The evidence included possession of cocaine; attempted murder of Braggs; reckless operation of Braggs’s vehicle; illegal carrying of a weapon; extortion (i.e., forcing Harris out of the truck at gunpoint); prostitution; possession of stolen goods (i.e., the two trucks and Braggs’s gun and clothes); and possession of drug paraphernalia. The trial court found that the evidence could be admitted and that Prieur notice was not necessary because the evidence was integrally related to Harris’s murder. After trial, the jury found Griffin guilty of first-degree murder, and she appealed.