Richard Benoit Versus Kirt Guerin, Warden Elayn Hunt Correctional Center

CourtLouisiana Court of Appeal
DecidedJanuary 18, 2023
Docket22-KH-547
StatusUnknown

This text of Richard Benoit Versus Kirt Guerin, Warden Elayn Hunt Correctional Center (Richard Benoit Versus Kirt Guerin, Warden Elayn Hunt Correctional Center) is published on Counsel Stack Legal Research, covering Louisiana Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Richard Benoit Versus Kirt Guerin, Warden Elayn Hunt Correctional Center, (La. Ct. App. 2023).

Opinion

RICHARD BENOIT NO. 22-KH-547

VERSUS FIFTH CIRCUIT

KIRT GUERIN, WARDEN ELAYN HUNT COURT OF APPEAL CORRECTIONAL CENTER STATE OF LOUISIANA

ON APPLICATION FOR SUPERVISORY REVIEW FROM THE TWENTY-NINTH JUDICIAL DISTRICT COURT PARISH OF ST. CHARLES, STATE OF LOUISIANA NO. 12,159, DIVISION "D" HONORABLE M. LAUREN LEMMON, JUDGE PRESIDING

January 18, 2023

SUSAN M. CHEHARDY CHIEF JUDGE

Panel composed of Judges Susan M. Chehardy, Stephen J. Windhorst, and Hans J. Liljeberg

WRIT GRANTED, IN PART, FOR LIMITED PURPOSE; WRIT DENIED, IN PART SMC SJW HJL COUNSEL FOR PLAINTIFF/RELATOR, RICHARD BENOIT Emily Posner

COUNSEL FOR DEFENDANT/RESPONDENT, KIRT GUERIN, WARDEN ELAYN HUNT CORRECTIONAL CENTER Honorable Joel T. Chaisson, II

COUNSEL FOR DEFENDANT/RESPONDENT, STATE OF LOUISIANA, DEPARTMENT OF JUSTICE Jeffrey M. Landry Grant L. Willis J. Taylor Gray CHEHARDY, C.J.

In this writ application, relator, Richard, Benoit, seeks review of the district

court’s September 20, 2022 judgment denying his supplemental application for

post-conviction relief (“APCR”). For the following reasons, we grant relator’s writ

application, in part, for the limited purpose of remanding the matter to the district

court for a ruling on relator’s claims raised in his supplemental APCR, which were

not reviewed on the merits; we deny relator’s writ application, in part, as to his

factual innocence claim.

FACTUAL BACKGROUND AND PROCEDURAL HISTORY

Relator was indicted by a grand jury on May 8, 2012, and charged with

aggravated rape of a minor under the age of thirteen, a violation of La. R.S.

14:42(A)(4)1, and aggravated incest of a minor under the age of thirteen, a

violation of La. R.S. 14:78.1.2 See State v. Benoit, 17-187 (La. App. 5 Cir.

12/29/17), 237 So.3d 1214, 1216. On April 10, 2014, after a four-day trial, a

unanimous jury found relator guilty of the responsive verdicts of sexual battery, in

violation of La. R.S. 14:43.1 (Count 1) and attempted aggravated incest, in

violation of La. R.S. 14:26 and La. R.S. 14:78.1 (Count 2). On July 30, 2014,

relator was sentenced to fifty years at hard labor, with thirty-five years to be served

without benefit of probation, parole, or suspension of sentence on Count 1, and

forty-nine and one-half years at hard labor on Count 2, to be served concurrently.

Relator’s convictions, as well as the sentence for sexual battery, were

affirmed by this Court on December 29, 2017. Benoit, 237 So.3d at 1216. Having

determined that relator’s sentence on the attempted aggravated incest conviction

was illegally lenient pursuant to La. R.S. 14:78.1(D)(2), as it was not imposed

without restriction of benefits, this Court remanded the matter for re-sentencing.

1 La. R.S. 14:42 was subsequently amended to rename the offense to first degree rape. 2 Aggravated incest was later re-designated as aggravated crime against nature, La. R.S. 14:89.1.

22-KH-547 1 Id. at 1225-26. Relator did not seek supervisory review by the Louisiana Supreme

Court. On July 24, 2018, the district court re-sentenced relator on Count 2 to forty-

nine and one-half years at hard labor, with twenty-five years to be served without

benefit of probation, parole, or suspension of sentence, to run concurrently with the

sentence imposed on Count 1. Relator did not move for reconsideration of the

sentence pursuant to La. C.Cr.P. art. 881.1, or appeal pursuant to La. C.Cr.P. art.

914. Accordingly, relator’s conviction and sentence became final thirty days later,

on August 25, 2018.

Relator timely filed his first application for post-conviction relief (“APCR”),

pro se, on July 10, 2020, raising the following claims: (1) ineffective assistance of

counsel (pre-trial and at trial); (2) excessive sentence; (3) Brady violation; (4)

prosecutorial misconduct; and (5) insufficient evidence to support the charge of

aggravated incest. The district court ordered the State to file an answer. On April

25, 2021, the State filed an answer arguing the relator’s claims lacked merit.

On June 23, 2021, after the State had filed its answer, the district court

granted relator’s unopposed Motion to Enroll and Set Deadline to Supplement

Application for Post-Conviction Relief, and set the filing deadline for October 15,

2021. After several extensions of time were granted, relator, through counsel, filed

a supplemental APCR on June 7, 2022—nearly two years after filing his original

pro se APCR—raising the following additional claims: (1) factual innocence

pursuant to La. C.Cr.P. art. 926.2;3 (2) relator’s confession and inculpatory

statements were false, unreliable, and coerced in violation of his due process

rights; (3) ineffective assistance of counsel, pre-trial and at trial; (4) ineffective

assistance of counsel during sentencing; (5) ineffective assistance of counsel on

appeal; and (6) cumulative error. As ordered by the district court, the State filed

3 La. C.Cr.P. art. 926.2, effective date of August 1, 2021, provides for a freestanding claim of factual innocence not based on DNA evidence.

22-KH-547 2 numerous procedural objections to relator’s supplemental APCR on September 8,

2022. Specifically, the State argued that relator’s claim of factual innocence failed

to meet the criteria set forth in La. C.Cr.P. at. 926.2, and additionally, that relator’s

remaining supplemental claims were untimely under La. C.Cr.P. art. 930.8(A).4

On September 20, 2022, the district court issued a judgment summarily

denying relator’s original and supplemental APCRs. As to relator’s pro se claims,

the district court found that the record failed to establish that relator’s counsel’s

performance was deficient or violated a duty owed to him. The district court also

found that the sentence imposed was not unconstitutionally excessive based on the

facts proven at trial, the details of the pre-sentencing investigation report, the

mitigating factors (including relator’s intoxication), and the age of the victim.

Relator was sentenced to concurrent terms of fifty years (ten years less than the

pre-sentencing report recommended), and forty-nine and one-half years.

According to the district court, neither of these terms was grossly disproportionate

to the severity of the offenses for which relator was convicted.

Additionally, the district court found no evidence of a Brady violation, and

that relator’s claim for such a violation is speculative at best. The district court

further found no merit to relator’s claim that the prosecutor was vindictive towards

him to the extent that it unduly prejudiced him. In particular, the trial court

concluded that relator failed to identify how he was prejudiced or how undue

prejudice affected the judgment of the jury. Relator also failed to demonstrate any

evidence that would support a mistrial pursuant to La. C.Cr.P. art. 770. According

to the district court, the verdict in this case was based on evidence submitted to the

jury, not the comments of counsel.

4 La. C.Cr.P. art. 930.8(A) provides, in pertinent part, that “[n]o application for post-conviction relief, including applications which seek an out-of-time appeal, shall be considered if it is filed more than two years after the judgment of conviction and sentence has become final.”

22-KH-547 3 Finally, regarding relator’s claim that the State failed to prove the existence

of a blood or legal relationship between himself and the victim, the district court

Free access — add to your briefcase to read the full text and ask questions with AI

Related

State v. Daigle
593 So. 2d 676 (Louisiana Court of Appeal, 1991)
State v. Allen
955 So. 2d 742 (Louisiana Court of Appeal, 2007)
State v. Littleton
982 So. 2d 978 (Louisiana Court of Appeal, 2008)
State v. Benoit
237 So. 3d 1214 (Louisiana Court of Appeal, 2017)
Campbell v. Louisiana Department of Transportation & Development
642 So. 2d 1273 (Supreme Court of Louisiana, 1994)
Muntz v. Lensing
668 So. 2d 1147 (Supreme Court of Louisiana, 1996)

Cite This Page — Counsel Stack

Bluebook (online)
Richard Benoit Versus Kirt Guerin, Warden Elayn Hunt Correctional Center, Counsel Stack Legal Research, https://law.counselstack.com/opinion/richard-benoit-versus-kirt-guerin-warden-elayn-hunt-correctional-center-lactapp-2023.