State v. Rodrigue

The State of Louisiana (plaintiff) charged Brenda Rodrigue (defendant) with second-degree murder based on the stabbing death of Rodrigue’s ex-boyfriend. Rodrigue told the police that she and her ex-boyfriend lived together for six months but had separated two weeks before the stabbing. Rodrigue indicated that on the day of the stabbing, she and her ex-boyfriend got into an argument, and the ex-boyfriend dragged Rodrigue to his house, where he held Rodrigue against her will, beat her, and raped her. Rodrigue told the police that her ex-boyfriend tried to have anal sex with her, but that she grabbed a knife, stabbed him, and ran away. At trial, Rodrigue asserted a justification defense to the murder charge. Rodrigue’s counsel said that Rodrigue intended to present evidence of the ex-boyfriend’s violent character under Article 404(A)(2) of the Louisiana Code of Evidence, which provided that evidence of the victim’s dangerous character could be admissible if the offense arose from a domestic-violence situation. However, the trial court ruled that the character evidence was inadmissible because Rodrigue and her ex-boyfriend were not in a relationship at the time of the stabbing. Rodrigue’s counsel then attempted to present testimony about the nature of the relationship between Rodrigue and her ex-boyfriend and the ex-boyfriend’s allegedly abusive treatment of Rodrigue during their relationship, but the trial court refused to admit the evidence. The jury found Rodrigue guilty, and the appellate court affirmed. Rodrigue appealed to the Louisiana Supreme Court.