Justia Louisiana Supreme Court Opinion Summaries

In 1996, Darrell J. Robinson was convicted of the brutal murders of four individuals, including a ten-month-old child, in Louisiana. The victims were shot in the head, and Robinson was sentenced to death based on the jury's recommendation. His conviction and sentence were affirmed by the Louisiana Supreme Court, and the U.S. Supreme Court declined to review the case. In 2005, Robinson filed for post-conviction relief, which was denied by the trial court in 2020. Robinson then sought review from the Louisiana Supreme Court, which initially set aside his conviction and sentence, citing due process violations due to the State's suppression of evidence and presentation of false testimony.The Louisiana Supreme Court granted a rehearing to reexamine its decision. Upon further review, the court found no merit in Robinson's claims of Brady violations, which alleged the State withheld favorable evidence, including deals with a jailhouse informant, forensic records, and eyewitness information. The court determined that the evidence was either not material or not favorable to Robinson's defense. The court also found no evidence of a pre-trial deal with the informant and concluded that the cumulative effect of the alleged Brady violations did not undermine confidence in the verdict.The court also addressed Robinson's claims of Napue violations, which alleged the State allowed false testimony. The court found no evidence that the testimony in question was false or that the State knew it was false. Additionally, the court rejected Robinson's claim of actual innocence, finding that the new evidence presented did not meet the high standard required to overturn the conviction.Ultimately, the Louisiana Supreme Court vacated its previous decision, reinstated Robinson's conviction and death sentence, and affirmed the trial court's judgment. The court found no abuse of discretion in the trial court's denial of Robinson's post-conviction relief application. View "State ex rel. Robinson v. Vannoy" on Justia Law

The case involves Jaylon K. Brown, who was charged with two counts of second-degree murder. The victims, Dararius Evans and Aleysia Maynor, were found shot in a vehicle. Brown, known as "Sneaks," initially denied involvement but later claimed self-defense in the shooting of Evans and accidental shooting of Maynor. He was convicted of second-degree murder for Evans and manslaughter for Maynor, receiving life imprisonment and a 40-year sentence, respectively.The District Court removed a juror, Bernadine Poole, for repeatedly sleeping during the trial. Brown's defense argued that this removal violated his rights as it occurred outside his presence and without a hearing. The Court of Appeal upheld the convictions and sentences, finding no error in the juror's removal, as her sleeping was a significant distraction and she failed to stay awake despite warnings.The Supreme Court of Louisiana reviewed the case. The court found that the District Court did not abuse its discretion in removing juror Poole, as she was unable to perform her duties due to her sleepiness. The court noted that defense counsel did not request a hearing or object to the juror's removal outside Brown's presence. The court held that the removal was justified given the juror's inability to stay awake during critical parts of the trial, including live testimony and video evidence. The Supreme Court of Louisiana affirmed the lower court's decision. View "State v. Brown" on Justia Law

In 2016, a five-year-old girl, B.J., disclosed to her grandmother, A.J., that her father, the defendant, had inappropriately touched her genitalia. This led to an investigation and the defendant being charged with sexual battery of a victim under the age of 13. At trial, B.J., then eight years old, testified that the incident occurred during an overnight stay at her adult sister’s home. The defendant denied the allegations.A Washington Parish jury found the defendant guilty in 2019. The trial court sentenced him to 40 years imprisonment at hard labor without the possibility of parole, probation, or suspension of sentence. The Court of Appeal, First Circuit, affirmed the conviction but remanded for resentencing due to a procedural error. On remand, the trial court reimposed the 40-year sentence. The defendant appealed again, arguing that the sentence was excessive given his age and the nature of the offense. The Court of Appeal affirmed the sentence.The Supreme Court of Louisiana reviewed the case and found the 40-year sentence excessive. The court noted that the defendant, a first-time sex offender in his mid-60s, received a sentence disproportionate to those imposed in similar cases. The court emphasized that while the crime was serious, a 25-year sentence without parole eligibility would be more appropriate and consistent with sentences in comparable cases. Consequently, the court reduced the sentence to 25 years imprisonment at hard labor without parole eligibility and remanded the case to the district court to update the commitment order. View "State v. Mangrum" on Justia Law

The defendant, Kathleen Mouton, was arrested on a charge of attempted second degree murder in Jefferson Davis Parish, Louisiana, on August 1, 2018. Before formal charges were filed, her defense counsel filed a motion for a preliminary examination. The State filed a bill of information charging Mouton with attempted manslaughter on June 13, 2019. The trial was scheduled six times but was continued each time. On August 17, 2022, Mouton filed a motion to quash based on untimely prosecution. The trial court granted the motion, reasoning that the motion for preliminary examination did not suspend the time limit to commence trial because it was filed before prosecution was formally initiated.The State appealed, and the court of appeal reversed the trial court's decision. The appellate court did not address whether the motion for preliminary examination suspended the limitation period. Instead, it found that the two-year limitation period was interrupted by the court closure in Jefferson Davis Parish due to the impact of Hurricane Laura. The court explained that the limitation period began running anew on August 27, 2020, and thus the State had two years from that date in which to commence trial. As such, the motion to quash filed on August 17, 2022, was premature and should have been denied.The Supreme Court of Louisiana disagreed with both the trial court and the court of appeal. It held that a motion for preliminary examination filed prior to the institution of prosecution does not suspend the time limitation to commence trial once charges are formally filed unless the defendant re-urges the motion after the State files the bill of information. The court also held that the limitation period was suspended, but not interrupted, when courts were closed due to Hurricane Laura. Based on these conclusions, the court found that the State failed to timely commence trial and reinstated the trial court’s grant of Mouton's motion to quash. View "State v. Mouton" on Justia Law

The case in question concerns the defendant, Sharrieff M. Kent, who was convicted by a Plaquemines Parish jury of two counts of aggravated assault with a firearm, one count of aggravated criminal damage to property, and one count of illegal discharge of a firearm. The charges stemmed from an incident where Kent fired several shots at a pickup truck containing law enforcement officers as they were fleeing his property during an investigation. Kent claimed he was protecting his family from unknown intruders on his property.The Court of Appeal had reversed Kent's convictions, determining that the State violated Kent's right to due process by introducing evidence of other crimes and his Fifth Amendment right to remain silent. The Court of Appeal also found that the State violated Kent’s right to remain silent by referencing his post-arrest, post-Miranda silence.However, the Supreme Court of Louisiana disagreed with the Court of Appeal's determinations. It concluded that the references made to the officers conducting the trash pull as part of a narcotics investigation do not constitute impermissible references to other crimes or misconduct. Additionally, the Supreme Court found that the State did not violate the Fifth Amendment as the circumstances presented align more with the exceptions and non-application of Doyle than with Doyle itself.While the Supreme Court agreed that the State introduced the facts underlying Kent's prior conviction without first satisfying necessary prerequisites to their admission, it did not believe this error warranted a reversal of Kent's conviction. Considering the overwhelming testimonial and physical evidence showing Kent fired his weapon at a fleeing vehicle in the street, the Supreme Court concluded that the verdict was surely unattributable to the error. Consequently, the Supreme Court reversed the ruling of the Court of Appeal and reinstated Kent's convictions and sentences. View "STATE OF LOUISIANA VS. KENT" on Justia Law

Darrell J. Robinson was convicted of four counts of first-degree murder and sentenced to death. Robinson appealed to the Supreme Court of Louisiana, arguing that the state suppressed material evidence that violated his due process rights. The evidence in question included undisclosed deals with jailhouse informant Leroy Goodspeed, serology reports and notes, other forensic evidence, and eyewitness accounts inconsistent with trial testimony.The court found that the state did suppress evidence and this evidence was favorable to the defense. The court further found that the undisclosed evidence was material and its suppression undermined confidence in the verdict. Consequently, the court decided that Robinson did not receive a fair trial, resulting in a verdict unworthy of confidence. The court reversed Robinson's conviction, vacated his sentence, and remanded the case for a new trial. View "STATE EX REL. ROBINSON VS. VANNOY" on Justia Law

In this case, the Supreme Court of Louisiana reviewed a conviction for domestic abuse battery involving strangulation. The defendant, Jose Sagastume, was found guilty by a unanimous jury and sentenced to three years imprisonment with two years suspended, followed by two years of probation. The defendant appealed his conviction, arguing that the trial court erred in denying his challenges for cause against two potential jurors: a retired police officer and a former assistant district attorney. However, the defense counsel did not object when the trial court denied these challenges.The Court of Appeal set aside the conviction, stating that despite the lack of formal objection, the defense counsel's reasons for the challenges and subsequent use of peremptory challenges to remove the jurors were sufficient to preserve the issue for review.The Supreme Court of Louisiana disagreed, ruling that according to the Code of Criminal Procedure art. 800(A), a defendant must object contemporaneously to a ruling refusing to sustain a challenge for cause in order to assign it as an error on appeal. The court found that the defense counsel's acquiescence without objection did not meet this requirement. Therefore, it reversed the ruling of the Court of Appeal, reinstated the conviction and sentence, and affirmed them. The court emphasized that the legislature's language in Article 800(A) was clear: an objection must be made at the time of the ruling, and the nature and grounds for the objection must be stated at that time. View "STATE OF LOUISIANA VS. JOSE M. SAGASTUME" on Justia Law

The Louisiana Supreme Court granted the State’s application to review the court of appeal’s determination that the State failed to prove that 16-year-old D.W. was the person who entered a sheriff’s vehicle and stole firearms from inside it, and therefore that the evidence was insufficient to support the delinquency adjudication for burglary involving a firearm, La. R.S. 14:62, and theft of a firearm, La. R.S. 14:67.15. After reviewing the record, the Supreme Court found the State presented sufficient evidence that D.W. was a principal, in accordance with La. R.S. 14:24, to these felony-grade delinquent acts regardless of whether he personally entered the vehicle and took the firearms that were inside it himself. Therefore, the Court reversed the ruling of the court of appeal and reinstated the delinquency adjudication and dispositions imposed by the juvenile court, which were then affirmed. View "Louisiana in the interest of D.W." on Justia Law

In October 2003, the state charged defendant William Lee, Jr. with one count of second degree murder. In 2007, a unanimous jury found defendant guilty as charged. The trial court sentenced defendant to life imprisonment at hard labor without benefit of probation, parole, or suspension of sentence. The conviction and sentence were affirmed on appeal. In October 2021, defendant and the District Attorney filed a “Joint Motion to Amend Conviction and Sentence Pursuant to La. C.Cr.P. art. 930.10.” In the motion, the parties stipulated to certain facts relating to the cause of the victim’s death: they agreed that new evidence obtained in May 2020 would have bolstered defendant’s case at trial by supporting the defense theory that the victim’s fatal injuries were caused by her falling on her own accord. Based on this new evidence, the parties agreed that “a fair and just resolution” of the case would be to amend defendant’s conviction from second degree murder to manslaughter, and for the court to vacate the life without parole sentence and impose a sentence of 35 years imprisonment at hard labor. The district court granted the joint motion, vacated defendant’s second degree murder conviction and the previously-imposed life without parole sentence, accepted defendant’s guilty plea to manslaughter, and imposed the agreed-upon 35-year sentence with credit for time served. In March 2022, the Louisiana Attorney General filed a pleading entitled, “Motion and Incorporated Memorandum to Vacate Post-Conviction Plea Agreement as Unconstitutional.” The Attorney General argued that Article 930.10 of the Code of Criminal Procedure unconstitutionally permitted courts to grant clemency to criminal defendants, a power that was expressly and exclusively granted to the governor. To this the Louisiana Supreme Court concurred, and reversed the district court and reinstated defendant's second degree murder conviction. View "Louisiana v. Lee" on Justia Law

The issue this case presented for the Louisiana Supreme Court's review was a matter of first impression: whether a defendant who is charged with first degree murder can elect a bench trial when the state has filed a formal notice that it will not seek capital punishment. The question presented involved the interpretation of Louisiana Code of Criminal Procedure article 780, specifically the meaning of the phrase “an offense other than one punishable by death.” In February 2021, defendant John Shallerhorn was arrested for several offenses, including on suspicion of first degree murder. The state filed notice that “for any charges for which the grand jury returns an indictment in [this] case, the State will elect to forego capital punishment.” Shallerhorn was ultimately indicted for first degree murder and armed robbery. Defendant filed a motion for a bench trial, seeking to waive his right to a trial by jury pursuant to the provisions of La. C.Cr.P. article 780. The state opposed this motion, and the trial court, agreeing with the state, denied it. The trial court noted that though the state was not currently pursuing the death penalty, “if something changes at the DA’s office and somehow death is back on the table,” then the defendant could not waive a jury and elect a bench trial. The Supreme Court held that after the state provides formal notice that it will not seek the death penalty, and thereby elects to prosecute the offense of first degree murder as a non-capital case, a defendant may waive a trial by jury and elect a bench trial. View "Louisiana v. Shallerhorn" on Justia Law