Adrian Broussard v. Warden E. Dustin Bickham

District Court, E.D. Louisiana·Decided June 18, 2026·No. 2:25-cv-02532·Unknown

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF LOUISIANA ADRIAN BROUSSARD CIVIL ACTION VERSUS NO. 25-2532 WARDEN E. DUSTIN BICKHAM SECTION “L”(4)

REPORT AND RECOMMENDATION

This matter was referred to a United States Magistrate Judge to conduct hearings, including an evidentiary hearing if necessary, and to submit proposed findings and recommendations pursuant to 28 U.S.C. § 636(b)(1)(B) and (C), and as applicable, Rule 8(b) of the Rules Governing Section 2254 Cases. Upon review of the entire record, the Court has determined that this matter can be disposed of without an evidentiary hearing. See 28 U.S.C. § 2254(e)(2).1 I. Factual and Procedural Background Petitioner Adrian Broussard (“Broussard”) is a convicted inmate incarcerated in the Dixon Correctional Institute in Jackson, Louisiana.2 On September 14, 2009, Broussard was charged in Terrebonne Parish by Bill of Information with attempted first-degree murder of a police officer.3 Broussard initially entered a plea of not guilty.4 Because there was no trial or appeal, the record is sparse on the facts underlying Broussard’s charge and arrest. According to state court pleadings and transcripts,5 on July 29, 2009, Deputy Donald Bourg responded to a call in a post office where Broussard was rolling a

1 Under 28 U.S.C. § 2254(e)(2), an evidentiary hearing is held only when the petitioner shows that either the claim relies on a new, retroactive rule of constitutional law that was previously unavailable or a factual basis that could not have been previously discovered by the exercise of due diligence and the facts underlying the claim show by clear and convincing evidence that, but for the constitutional error, no reasonable jury would have convicted the petitioner. 2 ECF No. 1. 3 ECF No. 7 at 3, Bill of Information, 9/14/09. The state court records are electronically filed at ECF No. 7. 4 Id. at 519, Minute Entry, 9/15/09. 5 Id. at 3, Bill of Information, 9/14/09; id. at 185-186, Sentencing Transcript, 3/3/10; id. at 83, Sanity Report, 2/23/10. joint of marijuana. During the altercation, Broussard shot Deputy Bourg three times, resulting in a bullet being lodged in the deputy’s spine and leaving him with a permanent limp. On April 27, 2010, Broussard entered a plea of guilty to attempted first degree murder of a police officer.6 On May 3, 2010, after a sentencing hearing, the state trial court sentenced

Broussard to 45 years in prison at hard labor without the benefit of probation, parole, or suspension of sentence.7 Broussard’s conviction and sentence became final 30 days later, on June 2, 2010, because he did not seek reconsideration of the sentence or move for leave to appeal. La. Code Crim. P. art. 914;8 Butler v. Cain, 533 F.3d 314, 317 (5th Cir. 2008) (“[A] conviction becomes final when the time for seeking further direct review in the state court expires.”) (quoting Roberts v. Cockrell, 319 F.3d 690, 694 (5th Cir. 2003)). Over two years later, on May 31, 2012, Broussard filed an Application for Writ of Mandamus with the Louisiana First Circuit Court of Appeal requesting a writ a mandamus for the state trial court’s failure to rule on his application for post-conviction relief.9 In his application for a writ of mandamus, Broussard attached his application for post-conviction relief signed March 5, 2012.10 On July 16, 2012, the Louisiana First Circuit granted Broussard’s writ for the sole purpose

of transferring his application for post-conviction relief to the state trial court for consideration.11 In his application for post-conviction relief, Broussard alleged the following claims: (1) the state trial court erred in accepting a constitutionally infirm guilty plea; (2) ineffective assistance of

6 Id. at 104, Boykin Form, 4/27/10; id. at 524, Minute Entry, 4/27/10. 7 Id. at 100; Sentencing Minute Entry, 5/3/10. 8Louisiana law requires a criminal defendant to move for leave to appeal within thirty (30) days of the order or judgment being appealed or a ruling on a timely motion to reconsider a sentence. La. Code Crim. P. art. 914 (as amended La. Acts 2003, No. 949, § 1). Failure to move timely for appeal under Art. 914 rendered the conviction and sentence final at the expiration of that period. State v. Counterman, 475 So.2d 336, 338 (La. 1985). 9 ECF No. 7 at 109-110, 1st Cir. Application for Writ of Mandamus, 2012-KW-0969, filed 5/31/12. 10 Id. at 116, Application for Post-Conviction Relief, signed 3/5/12. 11 Id. at 108, 1st Cir. Writ Order, 2012-KW-9069, 7/16/12. 2 counsel for failing to preserve his right to seek review of the lack of evidence against him, to properly investigate his case, and misinforming him of the terms of the plea agreement; (3) errors patent review; and (4) excessive sentence.12 Broussard also requested the state trial court grant him an out of time appeal for counsel’s failure to notify him of the right to appeal.13

On September 12, 2012, the State filed a response to Broussard’s application for post- conviction relief.14 On September 18, 2012, the state trial court set a hearing on October 24, 2012, and appointed counsel for Broussard to show cause why his application for post-conviction relief should not be dismissed as untimely.15 On October 24, 2012, after a hearing, the state trial court rejected Broussard’s application for post-conviction relief as untimely filed.16 It does not appear that Broussard sought review with either the Louisiana First Circuit Court of Appeal or the Louisiana Supreme Court. On March 14, 2013, Broussard filed a second application for post-conviction relief.17 In his second application, Broussard asserted the following claims: (1) he was denied due process when he involuntarily pled guilty under duress, coercion, and intimidation; (2) ineffective

assistance of counsel for counsel’s failure to adequately investigate his case, failing to object when it was discovered that he had mental conditions preventing him from understanding right from wrong before tending his guilty plea; and (3) the cumulative effect of constitutional errors effectuated denial of his equal protection and due process rights.18

12 ECF No. 7 at 119, Memorandum in Support of Application for Post-Conviction Relief, dated 3/5/12. 13 Id. 14 Id. at 311-14, State’s Response to Application for Post-Conviction Relief, 9/12/12. 15 Id. at 316, Trial Court Order, 9/18/12. 16 Id. at 525, Minute Entry, 10/24/12. 17 Id. at 335-40, Second Application for Post-Conviction Relief, 3/14/13. 18 Id. at 342-56, Brief in Support of Second Application for Post-Conviction Relief, 3/14/13. 3 After the State filed procedural objections, the state trial court dismissed Broussard’s second application as untimely on June 5, 2013.19 On October 8, 2013, the Louisiana First Circuit denied Broussard’s related writ application finding it untimely under La. Code Crim. Proc. art. 930.8.20 The Louisiana Supreme Court denied his related writ application on May 30, 2014, also citing La. Code Crim. Proc. art. 930.8.21

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