STATE OF LOUISIANA v. KAYLA JEAN GILES COUTEE (2026)

Writ application granted. See per curiam.

JDH

JBM

CRC

WHB

Supreme Court of Louisiana October 06, 2026

SUPREME COURT OF LOUISIANA

No. 2025-K-01611

STATE OF LOUISIANA

VS.

KAYLA JEAN GILES COUTEE

On Writ of Certiorari to the Court of Appeal, Third Circuit, Parish of Rapides

PER CURIAM

Writ granted. This matter was remanded to the appellate court to consider whether the trial evidence was sufficient to support Defendant's obstruction of justice conviction and; if the conviction is affirmed, to reconsider the unaddressed assignment of error that the 30-year sentence is excessive. State v Coutee, 23-1549 (La. 6/27/25), 413 So.3d 408. This court specified that, relative to the obstruction of justice charge, “The acts of this Defendant consist of giving her personal laptop to her sister and later instructing her sister to give it to a friend.”

On remand the appellate court concluded that, when viewed in the light most favorable to the prosecution, “the evidence shows that Defendant tried to conceal evidence of premeditation in a case in which she claimed self-defense,” and found Defendant's challenge to her conviction for obstruction of justice lacked merit.

We note that Defendant's defense of justification was based on her right to stand her ground, not self-defense. The appellate court, in addition to the evidence of the laptop, relied “more strongly” on the “uncontested fact that Defendant shot and killed her estranged husband.”

This court has noted that the State must disprove beyond a reasonable doubt the presumption provided by law in La. R.S. 14:20 that one is entitled to stand one's ground. Given the vacatur of Defendant's murder conviction, the appellate court's reliance on evidence of “premeditation” begs the question of whether there was premeditation of murder or premeditation to legally stand one's ground should the necessity arise.

The Court of Appeal also affirmed its previous decision that the 30-year sentence in this case was not excessive. The appellate court cites cases in which the defendant was convicted of aggravated battery, manslaughter, or murder and received lengthy sentences for obstruction of justice, without taking into account that this Defendant's conviction for murder has been vacated. Its opinion relies on the reasons of the trial court, noting “The trial court exhaustingly enumerated each factor it considered in rendering its sentence. Those factors are persuasive. Thus, for the reasons stated (citing its original opinion affirming the murder and obstruction of justice convictions) we affirm Defendant's sentence.”

The trial court's reasons were clearly tethered to the murder conviction. For example, the trial court discounted the factors of probation or the reoccurrence of criminal activity because Defendant would be serving a life sentence. Thus there has been no analysis of Defendant's sentence for obstruction of justice taking into account that the murder conviction has been vacated.

Accordingly, we remand this matter to the trial court to evaluate the conviction and sentence of Defendant for obstruction of justice considering the vacatur of the conviction for murder.

Weimer, C.J., concurs in the result and assigns reasons. Griffin, J., concurs in the result. Guidry, J., concurs in the results for the reasons assigned by Chief Justice Weimer.