State v. Ludwig

On December 7, 1979, Stephen Harr’s body was found in the street with gunshot wounds to the head and neck. A police investigation led detectives to Alfred Ludwig (defendant), who lived in a nearby motel. Detectives found blood and a spent bullet casing outside Ludwig’s motel room. Inside the room, officers saw more bullets and spent casings. Officers also observed blood on a piece of furniture and saw that a chest in the room had been shot. When a detective encountered Ludwig in the motel parking lot, the detective advised Ludwig of his constitutional right to avoid self-incrimination and then asked him about Harr. Ludwig initially denied knowing Harr, but he later told officers that Harr’s wife had killed Harr in Ludwig’s room with Ludwig’s gun. The State of Louisiana (plaintiff) charged Ludwig with first-degree murder, but the case ended in a mistrial. The state then charged Ludwig with second-degree murder. At Ludwig’s second trial, Ludwig sought to introduce evidence that Harr’s wife had either intentionally or unintentionally shot Harr in the foot or leg six months before the night of Harr’s death and that Harr’s wife was a beneficiary of Harr’s life-insurance policy. The trial court refused to admit Ludwig’s proffered evidence after finding, among other things, that the evidence was not relevant. The jury ultimately found Ludwig guilty of second-degree murder, and he appealed.