Justia Louisiana Supreme Court Opinion Summaries

Derroceus Abney was murdered on or about February 10, 2007. His body was found on or about February 23, 2007 hidden in an inoperable freezer. Investigators determined that the body had been moved to the freezer immediately after his murder. A fingerprint found at the scene was entered into a national database, and it was determined to be the fingerprint of defendant Channing Gray. Gray was arrested in 2013. The issue this case presented for the Louisiana Supreme Court's review was whether La. C.Cr.P. art. 576 could be applied to render timely the institution of a prosecution against defendant for obstruction of justice, following the dismissal of a prosecution for murder. The trial court denied the defendant’s motion to quash the bill of information charging him with obstruction of justice; however, the appellate court granted the defendant’s writ application, granted defendant’s motion to quash, and dismissed the bill of information. The appellate court concluded that the charge of obstruction of justice was not “based on the same facts” as the murder prosecution, contrary to the requirements of La. C.Cr.P. art. 576, and therefore was untimely filed. The Supreme Court disagreed with this, vacated the appellate court's judgment and reinstated the trial court judgment. View "Louisiana v. Gray" on Justia Law

Defendant Jeffrey Clark and a number of fellow inmates incarcerated at the Louisiana State Penitentiary in Angola, Louisiana (“Angola”) conspired to escape from prison. In furtherance of that plot, on the evening of December 28, 1999, they smuggled improvised weapons into the Angola education building, where various scheduled meetings and classes were taking place. There, they launched an attack on the prison guards present, hoping to obtain keys necessary to gain access to a nearby vehicle and to exit a secure access sally port to leave the prison and escape to Canada. The escape attempt was thwarted when prison officials discovered the disturbance and quickly surrounded the education building. Captain David Knapps, who had been taken hostage by the inmates, was bludgeoned and stabbed to death. Each inmate involved was tried separately, and Clark was convicted of the first degree murder of Captain Knapps and sentenced to death. On automatic appeal to the Supreme Court, defendant raised thirty-seven assignments of error, contending his conviction and sentence should be reversed. After a thorough review of the law and evidence, the Court found no merit in any of the assignments of error. Therefore, the Court affirmed defendant’s conviction and sentence. View "Louisiana v. Clark" on Justia Law

Defendant Joseph Taylor was charged with possession with intent to distribute (“PWITD”) cocaine and conspiracy to distribute cocaine. The state sought to introduce evidence of defendant’s three alleged prior convictions at trial: one PWITD cocaine and two for possession of cocaine. In accordance with Louisiana Code of Evidence article 404(B)(1) and "Louisiana v. Prieur," (277 So. 2d 126 (La. 1973)), the state filed two notices of intent to introduce such evidence, attaching the three police reports associated with these prior incidents to satisfy its burden of proof. The district court issued rulings allowing the state to introduce the other crimes evidence and the court of appeal denied defendant’s writ applications. The Supreme Court granted defendant’s two writ applications to address the correctness of the district court’s rulings and to re-examine the requirements and procedure for introduction of “other crimes, wrongs or acts” evidence at trial. The Court affirmed the ruling of the district court relative to the admissibility of defendant’s prior PWITD cocaine conviction. However, the Court reversed the district court’s ruling relative to the admissibility of defendant’s prior two convictions for possession of cocaine and remanded this matter back to the district court to conduct a pre-trial evidentiary hearing to determine the admissibility of this evidence. View "Louisiana v. Taylor" on Justia Law

Defendant Rodricus Crawford was indicted by grand jury for the first-degree murder of his one-year-old son, committed while engaged in the perpetration of cruelty to juveniles and second degree cruelty to juveniles and while the victim was under twelve years of age. Following the close of evidence, a jury unanimously found defendant guilty as charged and, after the penalty phase of the trial, recommended the death sentence. The trial court sentenced defendant to death in accordance with that recommendation. Defendant raised twenty-three alleged errors at trial as grounds to reverse the sentence; the Supreme Court found merit in only one: error relating to his “Batson challenge.” Defendant’s conviction and sentence were therefore vacated, and this matter remanded to the trial court for a new trial. View "Louisiana v. Crawford" on Justia Law

Defendant Robert McCoy was indicted by grand jury on three counts of first degree murder for the murders of Willie Ray Young, Christine Colston Young, and Gregory Lee Colston. After a trial, the jury found the defendant guilty as charged on all three counts. The trial court sentenced the defendant to death, in accordance with the jury’s determination. Defendant appealed his convictions and sentences, raising sixteen assignments of error. After a thorough review of the law and the evidence, the Louisiana Supreme Court found no merit in any of the assignments of error. Therefore, the Court affirmed defendant’s convictions and sentences. View "Louisiana v. McCoy" on Justia Law

In 2012, the sentencing provisions of La. C.Cr.P. art. 890.1 were replaced with new ones addressing sentencing. After numerous delays, defendant Sean Holloway was convicted and sentenced in 2014 for an offense committed in 2007. The offense occurred in 2007 prior to the legislative changes; the conviction and sentencing occurred following the effective date of those changes. The Supreme Court granted certiorari in this case to determine which version of La.C.Cr.P. art. 890.1 applied to the defendant’s sentence: the version in effect at the time of the offense, or the version in effect at the time of sentencing. After review of the language of the replacement article, which plainly stated that it applied “upon conviction, in sentencing the offender,” the Court found that it was the revised version of La. C.Cr.P. art. 890.1, effective May 17, 2012, that applied to defendant’s 2014 conviction and sentence, rather than the former version, in effect at the time of the offense. Therefore, the Court affirmed the decision of the court of appeal which vacated the designation of the defendant’s conviction as a crime of violence. View "Louisiana v. Holloway" on Justia Law

A jury found defendant Alden Morgan, committed armed robbery at age 17. Following return of the guilty verdict, the district court sentenced him to 99 years imprisonment at hard labor without benefit of parole, probation, or suspension of sentence. After being denied relief on direct review, defendant filed a motion to correct an illegal sentence in light of recent developments in Eighth Amendment jurisprudence pertaining to the sentencing of juveniles. The Louisiana Supreme Court granted the defendant’s writ application to determine whether the defendant’s 99-year sentence was an effective life sentence and was, therefore, illegal under the Supreme Court’s decision in "Graham v. Florida," (560 U.S. 48 (2010)). The Louisiana Court held that a 99-year sentence without parole was illegal because it did not provide the defendant “with a meaningful opportunity to obtain release based on demonstrated maturity and rehabilitation.” Accordingly, the Court amended defendant’s sentence to delete the restriction on parole eligibility. View "State ex rel Moran v. Louisiana" on Justia Law

Johnny Lee Harris was charged with the 2009 attempted armed robbery of Wayne Duplechain. He pleaded not guilty and proceeded to trial. During voir dire, the state opposed defense counsel’s exercise of peremptory challenge to strike three jurors, who all were white females. The jury found Harris guilty as charged of attempted armed robbery and the district court sentenced him to 30 years imprisonment at hard labor. A majority of the panel of the Court of Appeals rejected Harris’s claim that the trial court erred by granting the state’s “reverse-Batson” challenges regarding two of the three jurors, using "Louisiana v. Nelson," (85 So.3d 21 (La. 3/13/12)), as grounds for its ruling. The Supreme Court, however, found that the appellate dissent's assessment of the law and application was correct. The Supreme Court concluded that the district court erred in its handling of the state's "reverse-Batson" challenge, and therefore, the conviction and sentence, and remanded for further proceedings. View "Louisiana v. Harris" on Justia Law

Defendant Marcus Reed appealed after being convicted for the murders of three unarmed young brothers. Reed received the death penalty. On direct appeal to the Louisiana Supreme Court, Reed raised fifty alleged errors as grounds to overturn his convictions and sentence. After a "thorough" review of the record, the law, and the evidence, the Supreme Court found no reversible error. Accordingly, the Court affirmed defendant’s first-degree murder convictions and the imposition of the death sentence. View "Louisiana v. Reed" on Justia Law

In March 2014, the state charged defendant Dominick Sims by bill of information with one felony count of trafficking of children for sexual purposes, in violation of R.S. 14:46.3. During the course of pretrial proceedings, defendant filed a motion to quash, challenging the constitutionality of R.S. 14:46.3. The trial court ruled the statute unconstitutional, but after review, the Louisiana Supreme Court reversed, specifically finding that the provisions of R.S. 14:46.3(C)(2) were clear and unambiguous and did not conflict with R.S. 14:46.3(A)(1). View "Louisiana v. Sims" on Justia Law