Justia Louisiana Supreme Court Opinion Summaries

The Supreme Court granted certiorari in this case to determine whether the district court erred in sua sponte declaring that the jury waiver procedure described in the Louisiana Constitution (Article 1, section 17A) was unconstitutional for "depriving [Defendant] of his due process guaranteed under the 5th and 14th Amendments to the United States Constitution." Defendant Timothy Bazile was indicted for second degree murder. His trial was set for October, 2011. At a September hearing, Defendant indicated he wished to waive his right to a jury trial, and the State objected. The State argued that Defendant's waiver was less than forty-five days from the trial date, and pressed to continue with a jury trial. The district court expressed doubt as to whether the federal constitution allowed the State to tell a defendant he couldn't have a jury trial "even on the day it's set for trial." Defense ultimately asked for a continuance, and a bench trial was reset for a few days later than the original trial date. The court found that La. Const. art. I, sec. 17(A) "effectively allowed the state to 'force' a defendant into deciding whether to be tried by a judge or jury. However, 'the decision to have a bench trial or jury trial rests with the defendant." The State appealed the district court's decision. Upon review, the Supreme Court concluded that because the constitutionality of the jury waiver procedure was never raised by Defendant, the Court found that the district court erred in declaring the jury waiver procedure unconstitutional. View "Louisiana v. Basile" on Justia Law

In 2006, a Morehouse Parish grand jury indicted Defendant Lee Roy Odenbaugh, Jr., for the 2006 first degree murders of Jessie Mae Porter and Sondra Porter Odenbaugh and attempted first degree murder of Jessica Cooper. After the penalty phase, the jury unanimously recommended a sentence of death for each first degree murder count, finding Defendant knowingly created a risk of death or great bodily harm to more than one person. Defendant appealed his conviction and death sentence on the basis of thirty-six assignments of error. After careful review of all of Defendant's arguments on appeal, the Supreme Court affirmed his conviction and death sentence. View "Louisiana v. Odenbaugh" on Justia Law

Defendant Michael Anthony Wright was convicted by a jury of aggravated incest and sentenced to eighteen years imprisonment at hard labor. Finding the trial court erred in admitting certain evidence which was inadmissible pursuant to Louisiana Code of Evidence article 412.2, and in denying the Defendant's related motions for mistrial, the court of appeal reversed the conviction, vacated the sentence and remanded the matter for a new trial. The Supreme Court granted the State's writ application to review the correctness of the court of appeal's decision. Upon review, the Court vacated the decision of the court of appeal, and remanded the case for further proceedings, finding no abuse of discretion in the trial court's decision to allow evidence of the alleged victim's age to be submitted to the jury. Because the court of appeal found the admission of other crimes evidence constituted reversible error, it did not address defendant’s remaining assignment of error. View "Louisiana v. Wright" on Justia Law

The issue before the Supreme Court in this case involved the Court's appellate jurisdiction over cases in which a law or ordinance has been declared unconstitutional by the trial court. The district court declared Louisiana Code of Criminal Procedure article 496 unconstitutional under the Fourth and Fourteenth Amendments to the federal constitution, and Article I Section 5 of the state constitution. In October 2010, the State brought charges against Defendant Larry Rochon, alleging he committed theft over $500. The charges were brought by a bill of information; Defendant had not been arrested and may have been unaware of the state's action. When Defendant failed to appear at the arraignment, pursuant to article 496, the state sought a warrant for his arrest. A public defender assigned to Defendant's case challenged the warrant for lack of probable cause. In January 2011, Defendant appeared in court for the first time and received notice of his arraignment. At a subsequent hearing, the district court found no probable cause for the arrest. Later that year, the parties appeared for trial, but the state entered a nolle prosequi, notifying Defendant of the potential for reinstatement of the charge. The state filed a motion to dismiss the appeal which was ultimately denied by the Supreme Court in September 2011. After careful review of the trial court record and the applicable legal authority, the Supreme Court held that article 496 "must be read 'in pari materia' with La.C.Cr.P. article 202, such that a warrant may not issue on a bill of information unless an affidavit filed with the information shows probable cause for the arrest." The Court found that the district court erred in finding article 496 unconstitutional. View "Louisiana v. Rochon" on Justia Law

The issue before the Supreme Court on appeal was whether the Defendant Terrance Martin was "seized" when a police officer asked for his identification in order to check for outstanding warrants, then asked Defendant if he had anything illegal on his person while retaining the identification. Upon review of "the scant facts presented here," the Supreme Court found that there was nothing in the conduct of the officer which "decisively changed the consensual nature" of the officer's encounter with Defendant such that the Fourth Amendment protections were violated. Accordingly, the Court found that the district court did not abuse its discretion in denying Defendant's motion to suppress the drugs which he admitted having on his person. View "Louisiana v. Martin" on Justia Law

In 2006, Defendant Felton Dorsey and Randy Wilson were indicted by a Caddo Parish grand jury for the first degree murder of Joe Prock and attempted first degree murder of Bobbie Prock. The state subsequently dismissed the latter charge against both by amendment. A few months later, the State gave notice of its intention to seek the death penalty at Defendant's trial, alleging five aggravating factors. In 2009, the State filed an amended notice of intent to seek the death penalty, reducing the alleged aggravating factors to: (1) Defendant was engaged in the perpetration or attempted perpetration of aggravated rape, aggravated kidnapping, aggravated burglary, aggravated arson, aggravated escape, armed robbery or simple robbery; (2) Defendant knowingly created a risk of death or bodily harm to more than one person; and (3) Defendant offered, has been offered, has given, or has received anything of value for the commission of the offense. In his appeal, Defendant asserted twenty-six assignments of error from trial. After a thorough review of the law and evidence, the Supreme Court found none of the assignments of error constituted reversible error and therefore, the Court affirmed Defendant's conviction and sentence. View "Louisiana v. Dorsey" on Justia Law

Defendant Todd Jones made a graphic sexual request of a teenage boy. The issue before the Supreme Court was whether Defendant’s conduct was sufficient to constitute attempted indecent behavior with a juvenile. After reviewing the record and the applicable law, the Court found that in the specific context of this crime, the request was an "act" committed "for the purpose of and tending directly toward the accomplishing of his object" such that the attempt statute, La. R.S. 14:27, is satisfied. Therefore, the Court reversed the judgment of the appellate court and reinstated the jury verdict finding Defendant guilty of attempted indecent behavior with a juvenile. View "Louisiana v. Jones" on Justia Law

The Supreme Court was asked to determine whether the district court erred in declaring La. R.S. 15:560 et seq. unconstitutional. Defendants Bryan Golston, Paul Baker, Calvin Watson, Lloyd Dell and Reginald Jackson were soon-to-be-released sex offenders who had undergone the Sex Offender Assessment Panel (SOAP) process pursuant to La. R.S. 15:560 et seq. The district court found that the law was unconstitutionally vague as applied to the Defendants. Upon careful consideration of the legislative history of the SOAP process, the Supreme Court found the law to be a regulatory rather than criminal statutory scheme, and not subject to a void-for-vagueness analysis. Furthermore, even after applying a due process analysis, the Court found no violations. Accordingly, the Court reversed the lower court in each of the Defendants' cases and remanded the cases for further proceedings. View "Louisiana v. Golston" on Justia Law

The State charged Defendant John Mathieu with second degree kidnapping after an incident which Defendant, armed with a gun, confronted his ex-wife in a parking lot at her place of employment, forced her into her car and made her drive out of state. After a trial by jury, Defendant was found guilty as charged. Defendant conducted portions of the trial in his own right, including the cross-examination of his ex-wife and other State witnesses, which his court-appointed attorney conducted jury selection and other portions of the trial. Defendant was sentenced to thirty years' imprisonment at hard labor with the first two years without probation or parole. On appeal, the Fifth Circuit conditionally affirmed Defendant's conviction and sentence, but remanded the case to the trial court to determine whether Defendant made a clear and unequivocal request to represent himself and whether the judge made sufficient inquiries into Defendant's competency to waive counsel and represent himself. Upon review of the trial record, the Supreme Court found that nothing in the record suggested that Defendant was not capable of choosing his "hybrid" representation knowingly and voluntarily. The Court affirmed Defendant's conviction and sentence. View "Louisiana v. Mathieu" on Justia Law

The State charged Defendant Mervin White with driving while intoxicated. After a trial by jury in 2008, he was found guilty as charged. The trial court sentenced him to 20 years' imprisonment at hard labor without opportunity for probation or parole. The appellate court affirmed Defendant's conviction, but vacated his sentence as excessive and reduced it to a term of ten years. The State appealed, arguing that the evidence supported Defendant's 20-year sentence. Upon review of the applicable legal authority, the Supreme Court found that though Defendant's sentence fell within the upper range of sentences, it did not suggest an arbitrary departure "from a sentencing norm that might indicate disproportionate punishment." Accordingly, the Court reversed the appellate court and reinstated Defendant's 20-year sentence. View "Louisiana v. White" on Justia Law