When “Stand-Your-Ground” Trumps the Aggressor Doctrine:
An In-Depth Commentary on State of Louisiana v. Kayla Jean Giles Coutee (La. 2025)

1. Introduction

The Supreme Court of Louisiana’s per curiam decision in State v. Coutee, 2023-K-01549 (La. June 27, 2025) has significantly re-shaped the relationship between Louisiana’s stand-your-ground statute (La. R.S. 14:20) and the long-standing “aggressor doctrine” (La. R.S. 14:21). At issue was whether Kayla Jean Giles Coutee—who shot and killed her estranged husband, Thomas Coutee, during a custody exchange—was denied a fair trial when the jury received an instruction on the aggressor doctrine despite a statutory presumption in her favor under La. R.S. 14:20(B).

Overturning the conviction, the high court held that giving an aggressor-doctrine charge in a case governed by the statutory stand-your-ground presumption—without any evidentiary foundation that the defendant initiated the conflict—creates reversible error. The ruling vacates Coutee’s second-degree-murder conviction and sets new guardrails for trial courts statewide.

2. Summary of the Judgment

• The Third Circuit’s affirmance of Coutee’s convictions was reversed.
• The second-degree-murder conviction and mandatory life sentence were vacated.
• The obstruction-of-justice conviction was not disturbed, but the matter was remanded to the court of appeal to address sufficiency of evidence and excessiveness of the 30-year sentence.
• The Court declined to reach other assignments of error (ineffective assistance, juror challenges, etc.) because the erroneous instruction alone warranted relief.
• Chief Justice Weimer and Justices Guidry & Knoll dissented; Justices Hughes and Crain concurred.

3. Detailed Analysis

3.1 Precedents Cited

• La. R.S. 14:20 (Stand-Your-Ground / Justifiable Homicide) – Creates four justification scenarios and, in subsection B, a presumption that deadly force is reasonable when a person is in her dwelling, business, or vehicle and an unlawful and forcible entry is occurring.
• La. R.S. 14:21 (Aggressor Doctrine) – Bars an aggressor from claiming self-defense unless she withdraws.
• State v. Wilkins, 131 So.3d 839 (La. 2014) – Recognised no duty to retreat under stand-your-ground.
• Jackson v. Virginia, 443 U.S. 307 (1979) – Governs sufficiency-of-evidence review.
• Sullivan v. Louisiana, 508 U.S. 275 (1993); Chapman v. California, 386 U.S. 18 (1967) – Harmless-error framework for constitutionally defective instructions.
• State v. Williams, 483 So.2d 999 (La. 1986); State v. Revish, 185 So.3d 8 (La. App. 1 Cir. 2015)

The Court distinguished cases such as State v. Gasser and Ingram, emphasising that those decisions did not address improper jury instructions that effectively nullify the statutory presumption.

3.2 Legal Reasoning

1. Statutory Presumption is Potent
   La. R.S. 14:20(B) creates a legal presumption that the defendant’s belief in the necessity of deadly force is reasonable when the two enumerated conditions are met. The State must disprove that presumption beyond a reasonable doubt.
2. No Duty to Retreat
   Subsections C and D of R.S. 14:20 explicitly prohibit the jury from considering retreat. An aggressor-doctrine charge re-introduces the idea of withdrawal, undermining the statute.
3. Aggressor Doctrine Requires an Evidentiary Foundation
   Under Art. 802 La. C.Cr.P., charges must reflect “every phase of the case supported by the evidence.” Because no evidence showed Coutee provoked or initiated the confrontation, instructing on La. R.S. 14:21 was improper.
4. Conflict of Doctrines = Confusion = Reversible Error
   By telling jurors that an “aggressor cannot claim self-defense unless she withdraws,” while simultaneously telling them that a motorist has “no duty to retreat,” the court created incompatible directives. Applying Sullivan, the majority could not say the verdict was “surely unattributable” to the error.
5. Harmless-Error Analysis Failed
   The Third Circuit viewed the error as harmless, but the Supreme Court held the standard unmet where the instruction “seriously undermines both our state’s stand-your-ground laws and our citizens’ Second Amendment rights.”

3.3 Potential Impact

• Trial Practice: Judges must now carefully screen the evidentiary record before delivering an aggressor charge in any case invoking La. R.S. 14:20. Expect more pre-charge conferences and written rulings.
• Prosecution Strategy: The State bears an elevated burden to generate explicit evidence of “aggression” if it hopes to obtain the instruction; mere speculation will not suffice.
• Defense Strategy: Defense counsel will aggressively object to aggressor-doctrine charges and seek mistrials where the statutory presumption arises.
• Appellate Litigation: The decision supplies a new, defendant-friendly error paradigm; many pending appeals may cite Coutee to challenge convictions obtained with similar instructions.
• Legislative Clarification: The case may prompt lawmakers to codify—or further separate—the two doctrines, mirroring other states that place explicit “evidence-trigger” language in their self-defense statutes.

4. Complex Concepts Simplified

Stand-Your-Ground Law (La. R.S. 14:20)

A statute that lets a person use deadly force in very specific places (home, business, vehicle) if someone is unlawfully breaking in. When facts fit the statute, the law presumes the person’s fear is reasonable.

Aggressor Doctrine (La. R.S. 14:21)

If you start the fight, you cannot later claim self-defense unless you fully withdraw and communicate that withdrawal. Traditionally used in street fights or mutual combat situations.

Legal Presumption

A rule requiring the jury to accept a fact (here, reasonable fear) as true unless the opposing party disproves it beyond a reasonable doubt.

Harmless Error

Some mistakes at trial do not require reversal if an appellate court is convinced—beyond a reasonable doubt—that the error did not affect the verdict. Instructional errors that misdescribe reasonable doubt or allocate burdens generally are not harmless.

5. Conclusion

State v. Coutee crisply delineates the boundary between Louisiana’s statutory self-defense presumption and the judge-made aggressor doctrine. The Court’s majority admonishes that when a defendant is cloaked with the statutory presumption of reasonable fear, trial courts may not dilute that safeguard by layering on instructions that suggest a duty to withdraw or brand the defendant as the aggressor absent evidence.

Practically, the ruling elevates the evidentiary threshold for prosecutors and invites renewed scrutiny of self-defense jury charges across the state. More broadly, it re-affirms legislative supremacy: when the Legislature confers a presumption in favor of citizens who defend themselves in vehicles or homes, courts must apply it faithfully and avoid importing contrary common-law doctrines.

The decision heralds a new chapter in Louisiana self-defense jurisprudence—one that anchors jury instructions to statutory text and keeps the burden on the State where the Legislature placed it.