Justia Louisiana Supreme Court Opinion Summaries

Christopher Diano was convicted of a felony offense on March 3, 2023, for an act committed on January 24, 2021. The State sought to adjudicate Diano as a habitual offender based on three prior felony convictions from 2009, 2010, and 2013. Diano completed his parole for these offenses on December 25, 2015. Between then and the commission of the current offense, Diano was incarcerated for approximately 180 days for a misdemeanor conviction.Diano filed a motion to quash the habitual offender bill, arguing that more than five years had elapsed between his last felony conviction and the current offense, thus cleansing the predicate offenses under La. R.S. 15:529.1. The State contended that the five-year period had not elapsed because the 180 days of incarceration for the misdemeanor should be excluded from the calculation. The district court granted Diano’s motion, interpreting the statute to mean that the cleansing period is suspended only by incarceration related to the predicate felony offenses. The court of appeal denied the State’s writ application.The Supreme Court of Louisiana reviewed the case and affirmed the district court’s ruling. The court held that the time Diano spent incarcerated for a misdemeanor offense should be included in the calculation of the five-year cleansing period. The court reasoned that the statutory language must be read in conjunction with the entire statute and that the purpose of the Habitual Offender Law is to punish persistent felony offenses, not misdemeanors. The court also found that the State failed to prove that Diano remained under correctional supervision for the third predicate offense beyond December 25, 2015. Thus, the district court correctly granted Diano’s motion to quash the habitual offender bill. View "STATE OF LOUISIANA VS. DIANO" on Justia Law

The defendant was convicted in district court for second-degree murder under La. R.S. 14:30.1(A)(3) for providing drugs that led to the poly drug toxicity death of the victim. The incident involved the victim, Brittany Lapeyrouse, who died on September 19, 2018, after consuming various drugs. The defendant and two co-defendants were initially charged with multiple felonies, including negligent homicide. A superseding indictment charged the defendant alone with second-degree murder, possession of methamphetamine with intent to distribute, possession of alprazolam, and illegal carrying of weapons while in possession of controlled dangerous substances. The defendant pleaded not guilty, but a jury found him guilty on all counts.The Court of Appeal, Third Circuit, reversed the second-degree murder conviction, citing insufficient evidence. The appellate court noted that while there was evidence the defendant sold methamphetamine to the victim, there was no direct evidence that the victim ingested the methamphetamine sold by the defendant. The court also highlighted that the victim had access to drugs from other sources and was not in the defendant's company for extended periods on the day of her death. The appellate court concluded that the prosecution failed to exclude every reasonable hypothesis of innocence, as required by La. R.S. 15:438.The Supreme Court of Louisiana reviewed the case and affirmed the appellate court's decision. The court held that the evidence was insufficient to prove that the methamphetamine sold by the defendant was the direct cause of the victim's death. The court emphasized that the statute requires proof that the controlled substance distributed by the defendant was the direct cause of death, which was not established in this case. The court also noted that the State's expert could not definitively state that the methamphetamine alone caused the death, as the victim had multiple drugs in her system. View "STATE OF LOUISIANA VS. BARTIE" on Justia Law

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