State of Louisiana v. Khoi Q. Hoang

Summary

The court reversed the court of appeal and reinstated the defendant’s obstruction-of-justice conviction and sentence. It held that, viewing the evidence in the light most favorable to the prosecution, a rational jury could infer that the defendant removed the truck’s license plate or directed its removal to hinder the investigation of the murder. The court also held that the jury’s erroneous use of “and” in describing two alternative obstructive acts did not alter the sufficiency analysis because the jury was instructed on all statutory elements plus an additional requirement.