Justia Louisiana Supreme Court Opinion Summaries

The Supreme Court granted certiorari in this case to determine whether the court of appeal erred in ordering the return of $144,320 to Tina Beers after finding the State did not establish probable cause for forfeiture of her currency under the Seizure and Controlled Dangerous Substances Property Forfeiture Act of 1989 (the Act). Upon review of the matter, the Supreme Court found that the State proved there was probable cause for the forfeiture. Furthermore, the Court found that the court of appeal erred by reversing the decision of the district court to strike Tina Beers' claim to the money. The Court therefore reversed the decision of the court of appeal and reinstated the decision of the district court. View "Louisiana v. $144,320.00 Tina Beers, 132 Woody Lane, Silver City, NC 27344" on Justia Law

In 2006, a grand jury indicted Defendant Michael Garcia for first-degree murder of Matthew Millican (Matt). During his arraignment defendant pled not guilty. During trial on the merits, the presentation of the State’s case unfolded in a chronological fashion with five witnesses testifying to other unadjudicated crimes, including threats, aggravated battery, rape, and murder perpetrated by defendant while armed with a machete against victims in Michigan and Florida, followed by four witnesses who had exclusive knowledge of Matt’s murder. Thereafter, the defense called four guilt phase witnesses and then rested. After hearing closing arguments, receiving the District Court’s instructions, and deliberating defendant’s guilt for eleven minutes, the jury returned a unanimous verdict of guilty of first-degree murder. After trial on the penalty phase, the jury unanimously returned a verdict of death. The District Court denied defendant’s motion for new trial and sentenced defendant to death in accordance with the jury’s verdict. Defendant directly appealed his conviction and death sentence, raising eighty-five assignments of error. The Supreme Court addressed the "most significant" errors in its opinion, and the remaining errors were addressed in an unpublished appendix. After a thorough review of the law and the evidence, the Court affirmed defendant’s first-degree murder conviction and the imposition of the death sentence. View "Louisiana v. Garcia" on Justia Law

This criminal matter presented the res nova issue of whether a second arrest without a conviction for the charge of operating a vehicle while intoxicated (DWI) constitutes "a second violation of R.S. 14:98," which triggers the provisions of La. Rev. Stat. 32:667(I)(1)(a) (mandating the installation of an ignition interlock for the accused's refusal to submit to a chemical breath test following his arrest.) Plaintiff's license was suspended as a result of his refusal to take a breath test after his second arrest for DWI. When plaintiff was acquitted of this second DWI charge, he filed a rule to show cause why his license should not be immediately reinstated. Defendant-in-rule, Louisiana Department of Public Safety and Corrections, Office of Motor Vehicles (OMV), agreed plaintiff was entitled to have his license reinstated, but contended an ignition interlock device must be installed on his vehicle under La. Rev. Stat. 32:667(I)(1)(a) because of his refusal to submit to chemical testing after being arrested a second time for DWI. The District Court reinstated plaintiff's license without requiring an ignition interlock device, and the court of appeal affirmed, interpreting 'a second violation" as requiring a prior conviction. Upon review, the Supreme Court found that the second arrest on the charge of DWI was merely an allegation of a second violation, and did not constitute "a second violation of R.S. 14:98" in and of itself. The Court affirmed the lower courts' judgments reinstating plaintiff's license without restriction. View "Boudreaux v. Louisiana Dept. of Pub. Safety & Corr." on Justia Law

The issue before the Supreme Court in this case was whether defendant could be guilty of second degree murder for leaving her two small children home alone in the middle of the night, during which time a fire broke out and one of her children died in the fire. After reviewing the facts and the applicable law, the Court found that a conviction for second degree murder could not be supported where defendant’s criminally negligent act of leaving her young children alone in the middle of the night was not a "direct act" of killing, but was instead a criminally negligent act of lack of supervision which resulted in death. For that reason, the Court reversed the judgments of the lower courts and found defendant guilty of the lesser included offense of negligent homicide. View "Louisiana v. Small" on Justia Law

The Supreme Court granted a writ of certiorari in this case to determine whether the court of appeal erred in overturning Defendant’s conviction for aggravated burglary. Jerome Bryant, Jr. argued that the State failed to prove that he actually entered the victim's home. Finding the evidence sufficient to support the trial judge’s finding that Defendant entered the victim’s home, the Court reversed and reinstated the trial court's judgment. View "Louisiana v. Bryant" on Justia Law

Defendant James C. Magee was indicted by a grand jury for the first degree murder of Adrienne Magee, the first degree murder of Ashton Zachary Magee, the attempted first degree murder of S.M., and the attempted first degree murder of L.M. Following the close of evidence, the jury found the defendant guilty as charged on all counts and, at the conclusion of the penalty phase of the trial, recommended two sentences of death. In accordance with that recommendation, the district court sentenced the defendant to death by lethal injection for the murders of Adrienne and Zack Magee and to two consecutive terms of 50 years of imprisonment at hard labor without benefit of parole, probation or suspension of sentence for the attempted first degree murders of S.M. and L.M. Defendant appealed his convictions and sentences, raising seventeen assignments of error. "After a thorough review of the law and the evidence," the Supreme Court found no merit to any of Defendant's assignments of error, and affirmed his sentences and convictions. View "Louisiana v. Magee" on Justia Law

The state charged Defendant Ricky Cure by bill of information with possession of heroin in violation of La.R.S. 40:966. After the trial court denied his motion to suppress the evidence, Defendant entered a plea of guilty as charged, reserving his right to seek review of the trial court's adverse ruling on the suppression issue. The trial court sentenced him to four years imprisonment at hard labor, suspended, with four years of active probation. On appeal, the Fourth Circuit reversed Defendant's conviction and sentence on grounds that the trial court erred in denying the motion to suppress. The Supreme Court granted the state's application to review the decision below and reversed: "even assuming that [one of the responding officers] did not act reasonably when she opened the door of the Defendant's car, the lawful recovery of all of the evidence in the vehicle would have inevitably occurred once Defendant opened his hand at the officer's order and dropped the two papers of heroin onto the dashboard of the car." View "Louisiana v. Cure" on Justia Law

The state charged Defendant Courtney Savoy by bill of information with simple escape from the Winn Correctional Center in January of 2007. After trial by jury, Defendant was found guilty as charged and sentenced to the maximum term for the offense of five years' imprisonment at hard labor, to run consecutively to the sentence he was already serving at the time of the escape. At sentencing, the trial court specifically took into account Defendant's rap sheet which revealed 13 prior felony convictions. The court also considered as an aggravating factor that Defendant had (in the court's opinion) lied in his testimony at trial in which he denied any complicity in the escape. On appeal, the Third Circuit reversed Defendant's conviction and sentence on grounds that the trial court improperly precluded the defense from impeaching state witnesses with their prior inconsistent statements. On remand of the case, the state filed an amended bill of information charging Defendant with the more serious crime of aggravated escape. Defendant filed a pro se motion to quash the amended bill on grounds of prosecutorial vindictiveness in the substitution of a more serious charge for the original to punish him for success on appeal. The state rendered the motion moot by filing a third bill of information recharging Defendant with simple escape. After trial by jury in 2010, Defendant was again found guilty as charged and the trial court resentenced him. The state thereafter filed an habitual offender bill charging Defendant as a third offender on the basis of two sets of prior convictions entered on January 25, 2000, and on January 31, 2005. Defendant filed another pro se motion to quash, alleging selective prosecution and prosecutorial vindictiveness. The trial court denied the motion summarily and after a contradictory hearing, adjudicated Defendant a third felony offender. The court sentenced Defendant to ten years. On appeal, the Third Circuit affirmed Defendant's conviction but reversed his sentence as excessive and remanded for resentencing. The Louisiana Supreme Court granted the state's application for review and reversed the decision below: the Court concluded Defendant's sentence was excessive. The Court concluded resentencing Defendant as a habitual offender to a term of imprisonment twice as long as originally imposed did "not comport with due process of law." View "Louisiana v. Savoy" on Justia Law

The issue before the Supreme Court concerned whether the trial court erred in granting Defendant's motion to quash his indictment. In 2009, police found the victim, Ramon House, lying on the sidewalk, shot in the chest and ankle. He would later die from blood loss at the hospital shortly afterward. An eyewitness reported that Defendant Joshua Dion Williams, then age 19, and Defendant's friend, a juvenile, both shot the victim during a dispute over narcotics. In 2009, a grand jury indicted Defendant for second degree murder. In early 2010, Defendant filed a motion to quash the indictment, in which he contended that La.C.Cr.P. art. 404(B), (which provides that the judicial administrator of the 19th JDC shall perform the function of jury commission in East Baton Rouge Parish), is a special or local law prohibited by La. Const. art. III, sec. 12. Upon review, the Supreme Court found that the manner of selection of the grand jury was not "illegal. . . .In fact, the selection process comported exactly with La.C.Cr.P. art. 404(B), which is presumed to be constitutional. Defendant's complaint, then, [was] not that the manner of selection of the grand jury was illegal in that it violated Article 404(B), it [was] that Article 404(B), itself, [was] unconstitutional. . . . a person can challenge the constitutionality of a statute only if the statute seriously affects his rights, and, here, the Defendant has not made, or attempted to make, any showing that the Article does so." View "Louisiana v. Williams" on Justia Law

The state filed a delinquency petition in the Juvenile Court for the Parish of Orleans charging Defendant with distribution of heroin in violation of La.R.S. 40:966(A)(1). After a hearing, the court adjudicated Defendant delinquent and ordered him committed to the custody of the Department of Public Safety and Corrections for a period not to exceed one year. On appeal, the Fourth Circuit set aside the juvenile court's adjudication and disposition order on grounds that "any rational trier of fact, after viewing all of the evidence favorably to the prosecution, must have a reasonable doubt as to the Defendant's guilt." The Supreme Court granted the state's application for review and reversed the decision because the court of appeal erred in substituting its appreciation of the evidence presented at the delinquency hearing for that of the fact finder. View "In the interest of C.D." on Justia Law