State in the Interest of J.C.R.

CourtLouisiana Court of Appeal
DecidedMarch 4, 2015
DocketJAK-0014-1146
StatusUnknown

This text of State in the Interest of J.C.R. (State in the Interest of J.C.R.) 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
State in the Interest of J.C.R., (La. Ct. App. 2015).

Opinion

STATE OF LOUISIANA COURT OF APPEAL, THIRD CIRCUIT

14-1146

STATE IN THE INTEREST OF

J.C.R.

**********

APPEAL FROM THE OPELOUSAS CITY COURT PARISH OF ST. LANDRY, NO. JV9886 HONORABLE VANESSA HARRIS, CITY COURT JUDGE

DAVID KENT SAVOIE JUDGE

Court composed of Marc T. Amy, John E. Conery, and David Kent Savoie, Judges.

ADJUDICATION AND DISPOSITION VACATED. REMANDED FOR FURTHER PROCEEDINGS. Annette Roach Louisiana Appellate Project P. O. Box 1747 Lake Charles, LA 70602-1747 (337) 436-2900 COUNSEL FOR DEFENDANT/APPELLANT: J. C. R.

C.J. “Rusty” Ashley, II Assistant District Attorney P. O. Box 1999 Opelousas, LA 70571 (337) 948-2570 COUNSEL FOR PLAINTIFF/APPELLEE: State of Louisiana SAVOIE, Judge.

On February 28, 2014, the State filed a petition alleging that the Juvenile,

J.C.R., had violated La.R.S. 14:54.6, communication of false information

regarding a planned bombing on school property.1 Thus, the petition prayed that

he be adjudicated a delinquent. On July 16, the adjudication hearing began in

Opelousas City Court, and the second day of the hearing was July 24. The final

day of the hearing was August 13.

On September 3, 2014, the court held a dispositional hearing and ordered the

Juvenile to serve thirty-six months, suspended, with active supervised probation

for twenty-four months and a number of special conditions, including an 8 p.m.

curfew.

The Juvenile now seeks review by this court, assigning four errors. For the

following reasons, J.C.R.’s adjudication and disposition is vacated and the case is

remanded for further proceedings.2

FACTS

On February 26, 2014, an Opelousas 911 operator received a telephone call

that indicated there was a bomb at Opelousas Junior High School. One of the

Juvenile’s classmates testified that the Juvenile borrowed his phone on the day the

bomb threat was made. The Juvenile took the phone into the school’s locker room;

when he returned it, its screen showed that it was in “emergency mode.” Another

classmate testified he was in the locker room and heard the Juvenile make the

bomb threat.

1 The Juvenile is referenced by use of initials per Uniform Rules-Courts of Appeal, Rule 5-2. 2 It should be noted that we have reviewed the record for errors patent and find several, however, our ruling regarding the assignments of error render the errors patent moot. ASSIGNMENT OF ERROR NUMBER ONE

In his first assignment of error, the Juvenile argues the evidence adduced

against him at the hearing below was insufficient to support his adjudication as a

delinquent. The analysis for such claims is settled:

When the issue of sufficiency of evidence is raised on appeal, the critical inquiry of the reviewing court is whether, after viewing the evidence in the light most favorable to the prosecution, any rational trier of fact could have found the essential elements of the crime proven beyond a reasonable doubt. Jackson v. Virginia, 443 U.S. 307, 99 S.Ct. 2781, 61 L.Ed.2d 560, rehearing denied, 444 U.S. 890, 100 S.Ct. 195, 62 L.Ed.2d 126 (1979); State ex rel. Graffagnino v. King, 436 So.2d 559 (La.1983); State v. Duncan, 420 So.2d 1105 (La.1982); State v. Moody, 393 So.2d 1212 (La.1981). It is the role of the fact finder to weigh the respective credibility of the witnesses, and therefore, the appellate court should not second guess the credibility determinations of the triers of fact beyond the sufficiency evaluations under the Jackson standard of review. See State ex rel. Graffagnino, 436 So.2d 559 (citing State v. Richardson, 425 So.2d 1228 (La.1983)). In order for this Court to affirm a conviction, however, the record must reflect that the state has satisfied its burden of proving the elements of the crime beyond a reasonable doubt.

State v. Kennerson, 96-1518, p. 5 (La.App. 3 Cir. 5/7/97), 695 So.2d 1367, 1371.

We are unable to conduct the analysis, as video and audio exhibits played

during the adjudication hearing were not entered into evidence and thus are not

part of the record on appeal. The recordings were clearly important. Various

witnesses were asked by the State to identify themselves and the Juvenile on the

video recording or to identify his voice on the audio recording from 911. His

parents testified that the voice on the 911 tape was not his. The supreme court has

stated:

Both this court and the United States Supreme Court have made clear that a criminal defendant has a right to a complete transcript of the trial proceedings, particularly where appellate counsel was not counsel at trial. State v. Deruise, 98-0541, p. 11 (La.4/3/01), 802 So.2d 1224, 1234, cert. denied, 534 U.S. 926, 122 S.Ct. 283, 151 L.Ed.2d 208 (2001), citing Hardy v. United States, 375 U.S. 277, 84 S.Ct. 424, 11 L.Ed.2d 331 (1964) and State v. Robinson, 387 So.2d

2 1143 (La.1980). The Louisiana State Constitution guarantees that “[n]o person shall be subjected to imprisonment ... without the right of judicial review based upon a complete record of all evidence upon which the judgment is based.” LSA-La. Const. art. I § 19. Additionally, in all felony cases, the clerk or court stenographer shall record all of the proceedings, including the examination of prospective jurors, the testimony of witnesses, statements, rulings, orders, and charges by the court, and objections, questions, statements, and arguments of counsel. LSA-C.Cr.P. art. 843. The court reporter shall record all portions of the proceedings required by law and shall transcribe those portions of the trial proceedings required. LSA-R.S. 13:961(C).

Material omissions from the transcript of the proceedings at trial bearing on the merits of an appeal require reversal. State v. Landry, 97-0499 (La.6/29/99), 751 So.2d 214; Robinson, 387 So.2d at 1144. Although this court has found reversible error when material portions of the trial record were unavailable or incomplete, a “slight inaccuracy in a record or an inconsequential omission from it which is immaterial to a proper determination of the appeal” does not require reversal of a conviction. State v. Brumfield, 96-2667, pp. 14-16 (La.10/28/98), 737 So.2d 660, 669, cert. denied, 526 U.S. 1025, 119 S.Ct. 1267, 143 L.Ed.2d 362 (1999); State v. Parker, 361 So.2d 226, 227 (La.1978). A defendant is not entitled to relief because of an incomplete record absent a showing of prejudice based on the missing portions of the transcript. State v. Castleberry, 98-1388, p. 29 (La.4/13/99), 758 So.2d 749, 773, cert. denied, 528 U.S. 893, 120 S.Ct. 220, 145 L.Ed.2d 185 (1999); State v. Hawkins, 96-0766, p. 8 (La.1/14/97), 688 So.2d 473, 480.

State v. Boatner, 03-485, pp. 4-5 (La. 12/3/03), 861 So.2d 149, 152-53.

The supreme court has also stated:

[I]n State v. Landry, 97-0499 (La.6/29/99), 751 So.2d 214, a combination of loud construction noise at the courthouse and audio recording problems on the part of the court reporter rendered the record grossly incomplete in several respects, including the failure to record peremptory strikes and challenges for cause made at the bench. Landry, 97-0499 at 1-2, 751 So.2d at 215. This Court reversed the defendant’s capital conviction and sentence and remanded for a new trial because the deficiencies deprived the defendant of his constitutional right of appeal and judicial review. Landry, 97-0499 at 4, 751 So.2d at 216. The Court thereby reaffirmed that “it is not the defendant’s obligation to insure an adequate record . . . .

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Related

Hardy v. United States
375 U.S. 277 (Supreme Court, 1964)
Jackson v. Virginia
443 U.S. 307 (Supreme Court, 1979)
Strickland v. Washington
466 U.S. 668 (Supreme Court, 1984)
State v. Hawkins
688 So. 2d 473 (Supreme Court of Louisiana, 1997)
State v. Boatner
861 So. 2d 149 (Supreme Court of Louisiana, 2003)
State v. Kennerson
695 So. 2d 1367 (Louisiana Court of Appeal, 1997)
State v. Wry
591 So. 2d 774 (Louisiana Court of Appeal, 1991)
State v. Richardson
425 So. 2d 1228 (Supreme Court of Louisiana, 1983)
State v. Kinsey
976 So. 2d 315 (Louisiana Court of Appeal, 2008)
State v. Hilaire
45 So. 2d 360 (Supreme Court of Louisiana, 1950)
State v. Parker
361 So. 2d 226 (Supreme Court of Louisiana, 1978)
State v. Deruise
802 So. 2d 1224 (Supreme Court of Louisiana, 2001)
State Ex Rel. Graffagnino v. King
436 So. 2d 559 (Supreme Court of Louisiana, 1983)
State v. Brumfield
737 So. 2d 660 (Supreme Court of Louisiana, 1998)
State v. Duncan
420 So. 2d 1105 (Supreme Court of Louisiana, 1982)
State v. Landry
751 So. 2d 214 (Supreme Court of Louisiana, 1999)
State v. Moody
393 So. 2d 1212 (Supreme Court of Louisiana, 1981)
State v. Castleberry
758 So. 2d 749 (Supreme Court of Louisiana, 1999)
State v. Moore
575 So. 2d 928 (Louisiana Court of Appeal, 1991)
State v. Pinion
968 So. 2d 131 (Supreme Court of Louisiana, 2007)

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State in the Interest of J.C.R., Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-in-the-interest-of-jcr-lactapp-2015.