Justia Louisiana Supreme Court Opinion Summaries

Gerald Williams, an inmate in Louisiana, filed a suit for judicial review after the Louisiana Board of Pardons and Parole revoked his parole. Williams was originally convicted of armed robbery in 1985 and sentenced to 99 years without parole. After serving 28 years, he was released on parole in 2013. In 2021, Williams was arrested for aggravated assault, pleaded guilty to simple assault, and subsequently had his parole revoked. He later claimed his waivers of the revocation hearings were not knowing and voluntary and argued that his parole violation should be considered a "technical violation."The district court dismissed Williams' suit with prejudice, based on a recommendation from a commissioner, for failure to state a claim and because it was perempted under La. R.S. 15:574.11(D). The First Circuit Court of Appeal affirmed the district court's decision.The Supreme Court of Louisiana reviewed the case and addressed three main issues: whether Williams' petition was perempted, whether his procedural due process rights were violated, and whether his parole violation could be classified as a "technical violation." The court found that Williams' petition was perempted as it was filed 507 days after the parole revocation, well beyond the 90-day period allowed by law. The court also determined that Williams' waiver of his revocation hearings was knowing, intelligent, and voluntary, as he had signed and acknowledged the waiver in writing. Lastly, the court held that Williams' parole violation could not be classified as a "technical violation" due to his original conviction for a violent crime and his guilty plea to an intentional misdemeanor directly affecting a person.The Supreme Court of Louisiana affirmed the appellate court's decision to dismiss Williams' petition with prejudice. View "Williams v. Department of Public Safety and Corrections" on Justia Law

The applicant was convicted of second-degree murder by a Lafourche Parish jury for the shooting death of Deeric Raymond during a confrontation outside the applicant’s home. The incident occurred when Deeric and his brother Javonnie arrived to collect a debt and exchange custody of a child. A physical altercation ensued, resulting in Deeric’s death from a gunshot wound. The central issue at trial was whether the applicant acted in self-defense or was the initial aggressor. The jury rejected the self-defense claim and found the applicant guilty.The trial court sentenced the applicant to life imprisonment without parole. The Louisiana Court of Appeal affirmed the conviction, finding sufficient evidence to support the jury’s rejection of the self-defense claim. The applicant then filed for post-conviction relief, claiming ineffective assistance of counsel. The district court denied relief, stating no new evidence was presented that would have changed the jury’s verdict. The Court of Appeal denied writs without explanation, leading the applicant to seek review from the Supreme Court of Louisiana.The Supreme Court of Louisiana found merit in some of the ineffective assistance of counsel claims. The court determined that the applicant’s trial attorney failed to use available evidence to impeach the testimony of Javonnie, did not consult a forensic expert, and advised the applicant not to testify. These errors were deemed unreasonable and prejudicial, undermining confidence in the trial’s outcome. The court held that the applicant’s counsel’s performance fell below an objective standard of reasonableness and that there was a reasonable probability of a different outcome but for these errors. Consequently, the Supreme Court of Louisiana reversed the district court’s judgment, vacated the conviction and sentence, and remanded the case for a new trial. View "State v. Thomas" on Justia Law

D.D., a juvenile, was adjudicated delinquent for committing second-degree rape at the age of fourteen and was committed to the custody of the Office of Juvenile Justice until his twenty-first birthday. Upon release, he was required to register as a sex offender. D.D. challenged the constitutionality of this registration requirement, arguing it violated the Sixth and Eighth Amendments of the U.S. Constitution. The juvenile court denied his motion.D.D. appealed to the Court of Appeal, First Circuit, which affirmed both the adjudication and the denial of his constitutional claims. D.D. then sought review from the Supreme Court of Louisiana, which granted his writ application.The Supreme Court of Louisiana held that the sex offender registration requirement for juveniles does not constitute cruel and unusual punishment under the Eighth Amendment, as it is a civil regulatory measure intended to protect public safety rather than a punitive action. The court also found that the registration requirement does not implicate the Sixth Amendment's right to a jury trial, as juvenile proceedings are fundamentally different from adult criminal trials and do not require a jury trial for due process. The court affirmed D.D.'s adjudication and the denial of his motion to declare the registration requirement unconstitutional. View "In re D.D." on Justia Law

John and Analise Noehl were indicted for second-degree murder and cruelty to a juvenile after their seven-week-old son, D.N., was brought to the hospital with life-threatening injuries, including a skull fracture and healing rib fractures. Hospital staff alerted law enforcement due to the suspicious nature of the injuries. Detectives arrived, spoke with the parents at the hospital, and conducted separate interviews in a nearby room. The interviews were calm, lasted under 20 minutes each, and concluded with the parents being allowed to leave to accompany their child to another hospital.The 19th Judicial District Court granted the defendants’ motion to suppress the statements made during these interviews, finding that the parents were subjected to custodial interrogation without having received Miranda warnings. The court reasoned that the circumstances—such as being directed into a separate room, the presence of a homicide detective, and the officers’ actions—amounted to a significant restraint on the defendants’ freedom. The Louisiana First Circuit Court of Appeal denied the State’s writ application, leaving the suppression in place.The Supreme Court of Louisiana reviewed the case and reversed the trial court’s decision. The court held that, under the objective standard established by United States Supreme Court precedent, the defendants were not in custody for Miranda purposes during the hospital interviews. The court emphasized that the relevant inquiry is how a reasonable person in the suspects’ position would have understood the situation, not the subjective beliefs of the officers or the defendants. Because the interviews were brief, non-coercive, and the parents were free to leave afterward, the court concluded that Miranda warnings were not required. The case was remanded for further proceedings. View "STATE OF LOUISIANA VS. NOEHL" on Justia Law

The defendant, Davieontray Lee Breaux, was indicted on two counts of first-degree murder and three counts of attempted first-degree murder. The State issued a notice to seek the death penalty for the first-degree murder charges. Breaux filed a motion to quash the indictment, arguing misjoinder of offenses under various legal provisions, including the Louisiana Constitution. The trial court denied the motion, reasoning that since all convictions now require unanimity, the charges could be tried together.The Louisiana Third Circuit Court of Appeal denied Breaux's application for supervisory writs. Breaux then applied to the Louisiana Supreme Court, which granted the writ to determine whether prosecutors may join capital felony charges with other felony charges.The Louisiana Supreme Court held that prosecutors cannot join capital felony charges with other felony charges. The court emphasized that the Louisiana Constitution and nearly a century of jurisprudence prohibit such joinder. The court noted that the plain text of the Louisiana Constitution, specifically Article I §17, establishes distinct categories of felony trials and does not permit the joinder of capital and non-capital offenses. The court reversed the trial court's decision and remanded the case for further proceedings consistent with its opinion. View "STATE OF LOUISIANA VS. BREAUX" on Justia Law

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