Justia Louisiana Supreme Court Opinion Summaries

The Louisiana Supreme Court granted the State's petition for review to determine whether the court of appeal erred in reversing the district court's denial of post-conviction relief. The court of appeal found trial counsel’s representation fell below an objective standard of reasonableness under prevailing professional norms when a prospective juror was not challenged for cause for her employment with the district attorney. The court of appeal also found respondent suffered prejudice when that juror, initially an alternate, was then seated on the jury. The Supreme Court pretermitted the question of counsel’s deficient performance or error, finding legal error in the court of appeal’s prejudice determination under the Strickland v. Washington, 466 U.S. 668 (1984). "Here, the record does not establish prejudice. The verdict is neither unreliable nor would it have likely been different absent the alleged error. The court of appeal ruling is reversed and the ruling of the district court denying respondent’s application for post-conviction relief is reinstated." View "Louisiana v. Chandler" on Justia Law

The certiorari writ application in this case was granted by the Louisiana Supreme Court to address a purely legal issue: where a defendant’s convictions by a non-unanimous jury were final, but his sentences were still under review at the time Ramos v. Louisiana, 590 U.S. –––– (2020), was decided, is the defendant entitled to a new trial? The answer to this question was determined by whether the matter would be considered to be on “direct review” as contemplated by Louisiana v. Reddick, 351 So. 3d 273 (2022). The Louisiana Supreme Court found that only the direct review of the non-unanimous jury conviction entitled a defendant to a new trial. "Once that review is final, the defendant is not entitled to any further relief under Ramos, irrespective of whether his sentence or resentence is still on appeal." View "Louisiana v. Vaughn" on Justia Law

Defendant Qwandarious Rowe was charged by bill of information with possession of methamphetamine (less than two grams). The incident giving rise to defendant’s arrest occurred at a Washington Parish fair: a fair attendee alerted a sheriff’s deputy that a man in a public bathroom was sitting on the floor with his pants around his ankles. As the deputy pulled up defendant’s pants and assisted him out of the bathroom, he felt a syringe in defendant’s pocket, which he seized. The sergeant felt defendant required medical evaluation, and the fair’s emergency medical service (EMS) team was called. Defendant was carted off by gold cart for observation. Before the cart took defendant away, the deputy noticed something he believed to be methamphetamine sticking out of defendant's sock. Ultimately, EMS transported defendant by ambulance to a hospital where he was admitted with an altered mental status and was diagnosed with psychoactive substance abuse and an unspecified psychoactive substance abuse disorder. He was discharged about two-and-a-half hours later. The Louisiana Supreme Court granted this writ application to clarify the application of La.R.S. 14:403.10(B), which shielded a person from prosecution of possession of a controlled dangerous substance if it is discovered while that person is receiving needed medical assistance as a result of a “drug-related overdose.” The Court found that for the purpose of applying La.R.S. 14:403.10, “overdose” meant an acute medical condition, including, but not limited to, extreme physical illness, decreased level of consciousness, respiratory depression, coma, mania, hysteria, or death that is the result of consumption or use of a controlled dangerous substance, or a condition a lay person would reasonably believe was a drug-related overdose. The trial court here "manifestly erred" in rejecting defendant’s claim of immunity from prosecution under La.R.S. 14:403.10. Defendant presented sufficient evidence that he was, in fact, experiencing a drug-related overdose and, furthermore, his condition was such that a lay person would reasonably believe he was experiencing a drug-related overdose. Accordingly, the lower courts’ rulings were reversed, and defendant’s motion to quash was granted. View "Louisiana v. Rowe" on Justia Law

The property at issue was part of a larger tract purchased by Clarence Saloom in 1953 during his marriage to Pauline Womac Saloom. The entire tract was about 80 acres and became known as the “Pine Farm.” Plaintiffs were Clarence and Pauline’s three children: Patricia Saloom, Clarence Saloom Jr., and Daniel Saloom. Pauline died in 1973, and her one-half community interest in the Pine Farm was inherited by plaintiffs. A judgment of possession recognizing them as owners of Pauline’s one-half interest in the Pine Farm, subject to a usufruct in Clarence’s favor, was signed in 1974, and recorded in the public land records of Lafayette Parish. About two years later, the Louisiana Department of Highways (now the Department of Transportation and Development (the “state”)), contacted Clarence about purchasing a piece of the Pine Farm in connection with a project to widen and improve La. Highway 339. The instrument identifies Clarence as “husband of Pauline Womac Saloom” but does not mention Pauline’s death or plaintiffs’ inheritance of her interest in the property. Plaintiffs are not identified in the act of sale, did not sign it, and apparently were unaware of it for several years. In 1985, after learning of their father’s 1976 conveyance, plaintiffs hired an attorney who informed the state that plaintiffs owned an undivided one-half interest in the property. In 2015, about twenty years after Clarence’s death, the state began constructing improvements to Highway 339 on the property. Plaintiffs again contacted the state. In a May 18, 2016 letter, plaintiffs’ counsel confirmed the same information he had relayed to the state over thirty years earlier, specifically the state did not purchase all of the property in 1976 because Clarence only owned an undivided one-half interest. The state claimed to have acquired all interests in the property at issue and declined payment for plaintiffs' interest. Plaintiffs thereafter filed suit seeking damages for inverse condemnation. The Louisiana Supreme Court reversed the court of appeal judgment reversing the trial court’s judgment and granting the state’s motion for summary judgment was vacated. Because the court of appeal did not consider the state’s remaining arguments in support of its motion and in opposition to plaintiffs’ motion for summary judgment, the case was remanded the matter to the court of appeal for consideration of the state’s remaining assignments of error. View "Saloom v. Louisiana Dept. of Transportation & Dev." on Justia Law

Defendant Kenneth Gleason was convicted for the first-degree murder of Donald Smart, for which he received a life sentence. After giving notice he intended to appeal, Gleason died in prison. The court of appeal dismissed the appeal, vacated the conviction, and remanded the matter to the trial court with instructions to dismiss the indictment. The State appealed, arguing the Louisiana Supreme Court should overrule precedent adopting the abatement ab initio doctrine. To this, the Supreme Court concurred, finding that “[t]o abate a conviction would be as to say there has been no crime and there is no victim. Accordingly, we abandon the doctrine and hold that when a defendant dies during the pendency of an appeal, the appeal shall be dismissed and the trial court shall enter a notation in the record that the conviction removed the defendant’s presumption of innocence but was neither affirmed nor reversed on appeal due to the defendant’s death.” View "Louisiana v. Gleason" on Justia Law

Defendant Brian Clarke was charged with one count of home invasion. He provided notice of his intent to present the affirmative defense of voluntary intoxication at trial. In response, the State filed a motion in limine seeking to prohibit defendant from asserting an intoxication defense because, in the State’s view, home invasion was a general intent crime. The trial court granted the State’s motion. The court of appeal granted defendant’s writ application, and found that home invasion was a specific intent crime to which defendant was entitled to present voluntary intoxication as an affirmative defense. The Louisiana Supreme Court granted defendant’s application to determine whether the court of appeal correctly found that voluntary intoxication was an affirmative defense to the crime of home invasion. Based on the clear language of the statute that defines the crime of home invasion, La.R.S. 14:62.8, the Supreme Court agreed with the court of appeal that specific intent was a necessary element of the offense. "Therefore, whether voluntary intoxication is sufficient to preclude specific intent in this case is a question to be resolved by the trier of fact." Accordingly, the trial court erred in granting the State’s motion in limine to prohibit defendant from asserting voluntary intoxication as an affirmative defense. View "Louisiana v. Clarke" on Justia Law

Defendant Ladarious Brown was arrested for several offenses stemming from a domestic incident, but he was ultimately charged with two crimes: illegal use of weapons; and aggravated flight from an officer. A jury found defendant guilty as charged. The Louisiana Supreme Court granted defendant’s application to determine whether the court of appeal correctly applied Louisiana v. Mayeux, 498 So.2d 701 (La. 1986) in finding that defendant’s conviction for attempted aggravated flight from an officer was a nullity and therefore jeopardy had not attached. The Supreme Court found that it previously erred in its double jeopardy analysis in Mayeux, and the court of appeal erred here in deciding whether jeopardy had attached. Nevertheless, the court of appeal correctly vacated the conviction for attempted aggravated flight from an officer as a non-crime that was not responsive to the charge of aggravated flight from an officer. Accordingly, the Supreme Court reversed the court of appeal’s decision insofar as it found jeopardy had not attached, but otherwise affirmed the decision vacating the conviction for attempted aggravated flight from an officer. View "Louisiana v. Brown" on Justia Law

This case arose from a 2016 road rage incident that led to the shooting death of Joseph McKnight. A grand jury indicted the defendant Ronald Gasser for second degree murder. The case proceeded to a trial before a twelve-person jury in January, 2018. The jury was presented with a verdict sheet listing the crime of second degree murder and three responsive verdicts: guilty of manslaughter, guilty of negligent homicide and not guilty. By a vote of ten to two, the jury convicted defendant of the lesser included offense of manslaughter and defendant was sentenced to thirty years imprisonment at hard labor. While defendant's appeal was pending, the United States Supreme Court rendered its opinion in Ramos v. Louisiana, 140 S.Ct. 1390 (2020), holding that non-unanimous jury verdicts in state felony cases were unconstitutional. The Louisiana Supreme Court then granted defendant’s writ application and remanded the case to the Court of Appeal for patent review based on Ramos. Thereafter, and in accordance with Ramos, the Fifth Circuit found that defendant’s non-unanimous verdict entitled him to a new trial, vacated defendant’s conviction and sentence, and remanded the case to the trial court. The Louisiana Supreme Court granted certiorari to review when a non-unanimous jury finds a defendant guilty of a lesser, statutorily responsive verdict to a charged offense, valid at the time of its rendering, if the conviction was later set aside as unconstitutional, did double jeopardy preclude the State from retrying the defendant on the originally charged offense? The lower courts found that it did, and the Supreme Court agreed: double jeopardy barred the reinstatement and retrial of a defendant on a higher charge when he was lawfully convicted of a lesser included offense, even though the conviction was later vacated. The Court further agreed with the lower courts that, in this case, defendant’s conviction of a lesser included offense operated as an implied acquittal of the higher charge. View "Louisiana v. Gasser" on Justia Law

Defendant Chrystal Clues-Alexander was indicted for the second degree murder of her husband. She made two motions to declare former La.C.Cr.P. art. 782(A) unconstitutional, and require a unanimous jury at trial, which the district court denied. In 2018, she pleaded guilty to manslaughter. She pleaded guilty unconditionally and did not reserve any issues for review pursuant to Louisiana v. Crosby, 338 So.2d 584 (La. 1976). The Louisiana Supreme Court granted review to determine whether the court of appeal erred in ruling that defendant was entitled to withdraw her guilty plea based on Ramos v. Louisiana, 590 U.S. ___, 140 S.Ct. 583, 206 L.Ed.2d 583 (2020). At the time defendant pleaded guilty, the district court advised her that she had the right to a jury trial. After she pleaded guilty, the United States Supreme Court announced a new rule of criminal procedure in Ramos v. Louisiana, holding that a state jury must be unanimous to convict a criminal defendant of a serious offense. The Louisiana Court found that this jurisprudential development subsequent to defendant’s knowing and voluntary plea did not render her plea involuntary or unknowing. Accordingly, the Court reversed the ruling of the court of appeal and reinstated the district court’s ruling, which denied defendant’s motion to withdraw her guilty plea. View "Louisiana v. Clues-Alexander" on Justia Law

Defendant Mark Spell was the pastor of a church in Central, Louisiana. On March 31, 2020, he was issued six misdemeanor citations for violating two executive orders issued by Louisiana Governor Edwards in response to the COVID-19 pandemic. The Louisiana Supreme Court found certain provisions of those two executive orders, as applied to defendant, violated his fundamental right to exercise religion, did not survive strict scrutiny, and were thus unconstitutional. View "Louisiana v. Spell" on Justia Law