Justia Constitutional Law Opinion Summaries

The Louisiana Supreme Court granted review of this matter to determine whether the appellate court erroneously applied the domestic abuse battery statute, La. R.S. 14:35.3. The appellate court determined there was insufficient evidence to support the defendant’s conviction under the statutory provision requiring that an offender and victim be past or present members of the same household. As interpreted by the appellate court, La. R.S. 14:35.3 required the state to show the offender and victim engaged in a relationship comparable to the civil law concept of “open concubinage.” After that review, the Supreme Court found that the appellate court’s requirement that the state prove “open concubinage” between the victim and offender was not grounded in the statute. Moreover, the appellate court’s requirement of proof of “open concubinage” thwarts the broader inquiry into the circumstances of the relationship intended by the legislature. The Court reversed the appellate court and reinstated the trial court’s ruling that the totality of evidence was sufficient to find the victim and offender were part of the same household and, therefore, was sufficient to support the conviction. View "Louisiana v. Davis" on Justia Law

Defendant Corei Guidry was charged with one count of possession with intent to distribute heroin, one count of possession with intent to distribute cocaine, one count of possession with intent to distribute Tramadol, and one count of conspiracy to commit simple escape. The charge of possession with intent to distribute heroin carried the highest sentence: ten to fifty years at hard labor. The issue this case presented for the Supreme Court's review was whether the trial court could allow a criminal jury to be informed of the possible mandatory minimum sentence faced by the defendant if, after a conviction on the offense being tried, he were to be sentenced under the Habitual Offender Law. After review, the Court found the district court erred in denying the State’s motion in limine, which sought to disallow the defendant from mentioning in argument the mandatory minimum sentence the defendant could be subject to under the Habitual Offender Law should the State seek to enhance his sentence under that law and should the court find the State has proved all of the elements to warrant enhancement of the sentence. "We find the issue of the possible mandatory minimum sentences that may be imposed if the defendant is convicted and the State successfully pursues enhancement of the sentence under the Habitual Offender law is too attenuated from the guilt phase of trial to be discussed before a jury, because it shifts the focus of the jury from its duty to determine guilt or innocence to issues regarding sentencing, possibly causing confusion of the issues and inviting the jury to speculate as to why a defendant may be facing such a term of imprisonment." View "Louisiana v. Guidry" on Justia Law

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

Plaintiff Dana Johno filed suit against Plaquemines Parish Government (“PPG”) and numerous other defendants alleging his house was unlawfully demolished by PPG and its agents after Hurricane Katrina. The plaintiff subsequently moved to have La. R.S. 9:2800.17, which provided retroactive statutory immunity to the government and its agents for certain actions taken in the wake of Hurricane Katrina, declared unconstitutional. The District Court granted the plaintiff’s motion. Significantly, the issue of immunity was never raised or argued by PPG. Only one of the defendants, Hard Rock Construction, LLC, one of the contractors for PPG, appealed the District Court’s ruling. The Supreme Court affirmed: "When a party acquires a right to assert a cause of action prior to a change in the law, that right is a vested property right which is protected by the guarantee of due process. Thus, a cause of action, once accrued, cannot be divested by subsequent legislation." Because the plaintiff’s causes of action accrued before effective date of the statute, the statute was unconstitutional as applied in this matter. View "Johno v. Doe" on Justia Law

At issue in this case was a tax exclusion, La. R.S. 47:301(14)(g)(i)(bb), which provided exclusions from state and local sales tax of charges for repairs on certain property that was delivered to customers out of state. At the local tax level, the 2013 version of this tax exclusion was mandatory for tax authorities in East Feliciana Parish and optional for all other parishes, municipalities and school boards. The question presented for the Louisiana Supreme Court's review was, when the legislature enacted a tax exclusion, whether La. Const. art. VI, section 29(D)(1) required the legislature to treat tax authorities in all parishes the same or to make tax authorities in all parishes act the same. The Supreme Court held that the uniformity provision of the constitution, based on its plain and unambiguous meaning, required that a legislative tax exclusion treat tax authorities in all parishes the same. The Court found La. R.S. 47:301(14)(g)(i)(bb), as amended in 2013, to be unconstitutional because tax authorities in all parishes are not required to apply the tax exclusion in the same form, manner, or degree. "However, the portion of this statutory provision-mandating tax authorities in East Feliciana Parish apply the exclusion-is severable from the rest." Therefore, the Court severed this portion, leaving the balance of the statutory provision unchanged. Accordingly, the Court affirmed the district court ruling and remanded this matter to the district court for further proceedings. View "Arrow Aviation Co., LLC. v. St. Martin Parish Sch. Bd." 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

At the center of this appeal was a district court judgment declaring La. Child. Code art. 609 unconstitutional. La. Child. Code art. 609 required any statutorily defined “mandatory reporter” of child abuse “who has cause to believe that a child’s physical or mental health or welfare is endangered as a result of abuse,” to report the suspected abuse irrespective of “any claim of privilege.” Specifically, this case raised the issue of whether a priest was a “mandatory reporter,” as defined in La. Child. Code art. 603, when administering the Sacrament of Penance (“confession”), such that the provisions of La. Child. Code art. 609 would require him to report information learned during a sacramental confession. The Louisiana Supreme Court found that the issue here was one of statutory interpretation and should have been resolved on statutory grounds. Accordingly, the Court vacated the district court's declaration of unconstitutionality as premature and remanded this case for further proceedings. View "Mayeux v. Charlet" 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