Louisiana v. Quinn

After the jury could not reach a verdict in relator Landon Quinn’s first trial, the jury in relator’s second trial found him guilty of two counts of second degree murder in connection with the 2009 shooting deaths of Matthew Miller and Ryan McKinley. On the night of the shooting, an eyewitness told police that they would not find any shell casings because the shooter used a revolver. The following day, the eyewitness identified relator as the shooter from a photographic lineup. The eyewitness testified at both trials and unequivocally identified relator as the shooter. The convictions were affirmed on appeal. After direct review was completed, relator sought post-conviction relief on the ground that, inter alia, counsel rendered ineffective assistance at the second trial by failing to utilize a statement obtained from the eyewitness by a defense investigator. Specifically, the eyewitness told the defense investigator that the shooter’s hair was shorter than that depicted in a booking photograph taken at the time of relator’s arrest around 24–48 hours after the shootings. The defense investigator memorialized his interview with the eyewitness in an affidavit that was provided to counsel, who represented relator in his second trial but did not utilize the affidavit or call the investigator to testify. The district court granted relator a new trial after determining counsel at relator’s second trial were in possession of the affidavit and that the defense investigator would have made a compelling witness who could have challenged the strength of the eyewitness identification. The court of appeal denied the state’s writ application, finding the affidavit “strongly suggests that the defendant was mistakenly identified as the perpetrator.” The Louisiana Supreme Court reversed, finding that while the affidavit may have called into question the eyewitness’s ability to accurately discern the style of hair beneath a t-shirt worn over it, the likelihood of a different result if that information had been used at trial appeared conceivable but not substantial, and was insufficient to undermine confidence in the outcome of the second trial. View "Louisiana v. Quinn" on Justia Law