Justia Constitutional Law Opinion Summaries

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

After a bench trial, defendant Ashaki Kelly was convicted of molestation of a juvenile and sentenced to fifteen years at hard labor, without benefit of parole, probation, or suspension of sentence. The Supreme Court granted defendant’s writ application to determine whether the evidence presented at trial was sufficient to support his conviction, and whether the court of appeal erroneously vacated defendant’s sentence as illegally lenient on errors patent review. After review, the Supreme Court affirmed that portion of the court of appeal’s ruling which upheld defendant’s conviction. However, the Court found that the court of appeal failed to conduct a proper errors patent review and erred in vacating defendant’s sentence. View "Louisiana v. Kelly" on Justia Law

Following deliberations, a six-person jury found defendant Gerald Dahlem guilty on a fourth offense of Driving While Intoxicated (DWI), and the trial court sentenced defendant as a habitual offender to 25 years without benefit of parole, probation, or suspension of sentence. The court of appeal affirmed both defendant’s conviction and his sentence. The Louisiana Supreme Court granted the writ application in this case to determine whether trial by a jury composed of fewer jurors than required by law was a non-waivable structural defect which required that a defendant’s conviction be reversed and his sentence vacated. Specifically, the narrow question before the Court was whether defendant was denied a fair trial and due process of law because he was, without contemporaneous objection at trial, tried by a six-person jury, instead of a twelve-person jury, on his DWI charge. The Court found that due to defendant’s multiple offender status and subsequent sentence as such, his trial by a six-person jury was not an error requiring his conviction be reversed or his sentence vacated. View "Louisiana v. Dahlem" on Justia Law

A grand jury indicted Robert Coleman with for the first-degree murder of 70-year-old Julian Brandon, Jr., and the attempted first-degree murder of Brandon’s wife, Alice. A jury later found Coleman guilty and voted for the death penalty. The Louisiana Supreme Court found a “Batson” violation and remanded for a new trial. A second jury also found Coleman guilty and again voted for the death penalty. Defendant appealed his conviction and sentence raising 38 assignments of error, variously combined into 21arguments. After a thorough review of the law and the evidence, the Louisiana Supreme Court found no merit in any alleged error relative to the issue of guilt. Therefore, the Court affirmed defendant’s first-degree murder conviction. However, the Court found error relative to the state’s failure to provide sufficient notice of evidence of an unadjudicated murder introduced in the penalty phase. Thus, the Court vacated defendant’s sentence and remanded this case for a new sentencing hearing. View "Louisiana v. Coleman" on Justia Law

The issue this case presented for the Supreme Court's review centered on the allotment system of criminal cases in Orleans Parish Criminal District Court when the date of the offense is uncertain, specifically, whether La. Dist. Ct. Rule 14.0 or the defendants’ due process rights are violated by the case allotment system of the Orleans Parish Criminal District Court, which randomly assigns cases to different District Judges based on the first date of the first alleged offense. Defendants argued the procedure in place at the time of the allotment of their cases was unconstitutional as applied to multi-count, multi-defendant cases, or to cases in which the date of offense is uncertain and in which the prosecutor has discretion to allege the earliest date of a charged offense. Upon review, the Supreme Court found the Orleans Parish Criminal District Court’s allotment process was sufficiently random and did not vest the District Attorney with the power to choose the Judge to whom a particular case is assigned, instead tethering judicial assignment to the defendant’s conduct. As defendants presented no evidence of actual manipulation or prejudice, the Court reversed the Court of Appeal granting the motions to quash allotment and ordering re-allotment, reinstate the trial courts’ denials of the defendants’ motions to quash and/or for re-allotment, and remanded these cases to their respective trial courts for further proceedings. View "Lousiana v. Nunez" on Justia Law

The Louisiana Supreme Court granted certiorari in this matter to determine whether the lower courts erred in allowing certain expert psychological testimony as to the victim’s intelligence quotient (IQ) and in admitting into evidence a letter written by the expert which contained hearsay evidence. Defendant Vernon Mullins was indicted for the aggravated rape of J.W. He was sentenced to life imprisonment without benefit of probation, parole, or suspension of sentence. Defendant raised issues he claimed the trial court made that warrant reversal of sentence: (1) allowing Dr. Mark Vigen, the State’s expert psychologist, to present evidence as to the results of IQ testing he did not administer or score violated the Confrontation Clause of the United States Constitution; (2) the lower courts erred in allowing hearsay testimony and the introduction into evidence of a letter Dr. Vigen prepared in advance of trial, both of which were based on information gained from persons who did not testify; (3) the lower courts erred in allowing the introduction of Dr. Vigen’s letter, where the letter contained hearsay, not subject to any exception; and (4) the court of appeal erred in failing to find that the trial court had erred in allowing expert testimony where the State failed to comply with Article 705(B) of the Code of Evidence. After review, the Supreme Court found that the letter containing the IQ test results and introduced by the State for the primary purpose of proving an essential element of the crime of aggravated rape contains testimonial statements and therefore was subject to Confrontation Clause requirements. As a result, the trial court violated defendant's Sixth Amendment rights by ruling the letter could be admitted into evidence without testimony. Furthermore, the Court found that the introduction of the letter violated the hearsay rule. Accordingly, the Court reversed the decisions below, vacated Defendant's conviction and sentence, and remanded this case to the District Court for a new trial. View "Louisiana v. Mullins" on Justia Law