State of Louisiana v. Calvin King

Summary

The court held that a trial court granting a new trial under Louisiana Code of Criminal Procedure article 851(1) need not make a separate, reviewable finding that an injustice occurred. Because the ruling is based on factual assessment of the evidence and credibility, appellate courts may not reweigh those matters in a criminal case, absent a demonstrable legal error or lack of factual support. The appellate court's judgment was therefore reversed and the trial court's order granting a new trial was reinstated.