State of Louisiana v. Arthur Anderson

CourtLouisiana Court of Appeal
DecidedApril 10, 2024
Docket55,550-KA
StatusPublished

This text of State of Louisiana v. Arthur Anderson (State of Louisiana v. Arthur Anderson) 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 of Louisiana v. Arthur Anderson, (La. Ct. App. 2024).

Opinion

Judgment rendered April 10, 2024. Application for rehearing may be filed within the delay allowed by Art. 922, La. C. Cr. P.

No. 55,550-KA

COURT OF APPEAL SECOND CIRCUIT STATE OF LOUISIANA

*****

STATE OF LOUISIANA Appellee

versus

ARTHUR ANDERSON Appellant

Appealed from the First Judicial District Court for the Parish of Caddo, Louisiana Trial Court No. 345,027

Honorable John D. Mosely, Jr., Judge

LOUISIANA APPELLATE PROJECT Counsel for Appellant By: Douglas Lee Harville

ARTHUR ANDERSON Pro Se

JAMES E. STEWART, SR. Counsel for Appellee District Attorney

TOMMY JAN JOHNSON KODIE K. SMITH MEKISHA SMITH CREAL Assistant District Attorneys

Before STONE, STEPHENS, and MARCOTTE, JJ. STEPHENS, J.

This criminal appeal arises out of the First Judicial District Court,

Parish of Caddo, State of Louisiana, the Honorable John Mosely, Jr.,

presiding. Defendant, Arthur Anderson, was convicted by a unanimous jury

of the second degree murders of Ashley Williams and Huey Leonard. The

trial judge sentenced Anderson to the mandatory term of life imprisonment

without benefits on each conviction and ordered the sentences to be served

consecutively. Appellate counsel has appealed the sentence as excessive,

and Anderson has filed a pro se brief urging insufficiency of the evidence

and error in the trial court’s ruling on the admissibility of Ms. Williams’

dying declarations identifying Anderson as the man who shot her and

Leonard. For the reasons set forth below, we affirm Anderson’s convictions

and sentences.

FACTS/PROCEDURAL HISTORY

Russell Nicholson and Erica Johnson heard multiple gunshots from

inside their home on Crosby Street on the evening of November 19, 2016.

After hearing an SUV speed off, Nicholson and Ms. Johnson walked

outdoors to find a blue car wrecked in the ditch just outside of their home.

Ashley Williams, whom Nicholson recognized, had managed to crawl out of

the driver’s side of the blue Nissan Versa and was lying in the ditch. At

trial, Ms. Johnson testified that Ms. Williams repeated several times, “Arthur

[Anderson] shot us.” Ms. Williams’ passenger, Huey Leonard, was

unresponsive in the blue Versa.

Earlier that evening, Ms. Williams had seen her ex-boyfriend,

defendant, Arthur Anderson, at a gas station in a tan SUV, and he had

confronted her about being in a relationship with Leonard. Although Anderson allegedly had a girlfriend living with him in his mother’s home, he

was still trying to control Ms. Williams, who had told several friends and

family members about her fear of him.

Shreveport Police Department Sergeant Charles Rose responded to the

911 call and was able to speak with the victim Ashley Williams. Sgt. Rose’s

mobile vision system (“MVS”) recorded Ms. Williams telling responding

officers that Arthur Anderson shot her. Ms. Williams also reported that

Anderson was driving a tan SUV. Ms. Williams’ cell phone records showed

that Anderson called her 36 times the day of the homicides.

Further investigation revealed body damage to Ms. Williams’ blue

Versa that matched up to contact with the tan SUV driven by Anderson that

night.1 The murder weapon that killed Ms. Williams and Leonard was a .45

caliber semi-automatic handgun—Anderson was known to use a .45. The

shots killing Ms. Williams and Leonard were fired at close range, and shell

casings, bullet casings, and a bullet were found in the tan SUV driven by

Anderson. Phone records tracked both Anderson’s and Ms. Williams’

mobile phones’ movements, which also linked Anderson to the murders.

However, there were no fingerprints or DNA that linked Anderson to the

homicides.

Anderson was arrested, and on February 16, 2017, a Caddo Parish

grand jury indicted him with two counts of second degree murder, violations

of La. R.S. 14:30.1, for the murders of Ashley Williams and Huey Leonard.

On February 22, 2017, Anderson pled not guilty after being formally

1 The tan SUV is registered to and owned by defendant’s ex-girlfriend, Debra Hayes, who lived with Anderson and his mother. Ms. Hayes was involved in hiding the SUV after the murder and repeatedly lied to police during the investigation. 2 arraigned. Jury selection took place October 24 and 25, 2022. Trial was

held October 26-28, 2022. On October 31, 2022, the jury returned

unanimous verdicts of guilty on both counts.

A motion for new trial was filed on November 9, 2022. A hearing on

the motion was held on November 30, 2022, following which the motion

was denied. On that same date, the trial court sentenced Anderson to

consecutive terms of life imprisonment at hard labor without the benefit of

probation, parole, or suspension of sentence. An out-of-time motion for

appeal was filed on February 7, 2023. Both appellate counsel and defendant

have filed briefs.

DISCUSSION

Sufficiency of the Evidence

In his first assignment of error, Anderson urges that the evidence was

insufficient to support his convictions for two counts of second degree

murder. Anderson contends that several of the trial court’s evidentiary

rulings, including those allowing into evidence statements made by Ms.

Williams as she was dying, and his and Ms. Williams’ cell phone records,

were erroneous, and that there was insufficient evidence to prove

Anderson’s identity as the person who shot Ms. Williams and Leonard.

He claims that Ashley Williams’ inadmissible statements (to Ms.

Johnson that Arthur Anderson “shot them,” and to Sgt. Rose, in response to

his question, “Who did this to her?”, “Arthur Anderson”) were not dying

declarations but were instead inadmissible hearsay. Even so, contends

Anderson, these statements were insufficient to prove his identity as the

shooter. As to the cell phone records, Anderson urges that they do not show

who was using the phone at the time in question, and likewise, was 3 insufficient to prove Anderson was the person who shot Ms. Williams and

Leonard.

According to Anderson, there was no direct evidence that he was the

person who shot Ms. Williams and Leonard. Because the State failed to

negate any reasonable possibility of misidentification beyond a reasonable

doubt, no reasonable juror could have believed the “conflicting testimony

and conjecture” of the witnesses. Anderson urges that the identifications of

him as the shooter related by Ms. Williams to Sgt. Rose, Sgt. Clinton

Grigsby, Ofc. Jamie Bryant, Russell Nicholson, and Erica Johnson were all

hearsay and were the only direct unbiased evidence used to convict him.

This shows that the admission of this alleged “dying declaration” evidence

was far from harmless, contends Anderson.

Defendant was convicted of two counts of second degree murder in

the deaths of Ashley Williams and Huey Leonard. Second degree murder is

the killing of a human being when the offender has a specific intent to kill or

inflict great bodily harm. La. R.S. 14:30.1. Specific intent is that state of

mind which exists when the circumstances indicate that the offender actively

desired the prescribed criminal consequences to follow his act or failure to

act. La. R.S. 14:10(1). Specific intent may be inferred from the

circumstances surrounding the offense and the conduct of the defendant.

State v. Bishop, 01-2548 (La. 1/14/03), 835 So.

Related

Jackson v. Virginia
443 U.S. 307 (Supreme Court, 1979)
Robertson v. Casual Corner Group, Inc
541 U.S. 905 (Supreme Court, 2004)
State v. Timon
683 So. 2d 315 (Louisiana Court of Appeal, 1996)
State v. Carlisle
315 So. 2d 675 (Supreme Court of Louisiana, 1975)
State v. Smith
661 So. 2d 442 (Supreme Court of Louisiana, 1995)
State v. Dotie
1 So. 3d 833 (Louisiana Court of Appeal, 2009)
State v. Casey
775 So. 2d 1022 (Supreme Court of Louisiana, 2000)
State v. Pigford
922 So. 2d 517 (Supreme Court of Louisiana, 2006)
State v. Wright
445 So. 2d 1198 (Supreme Court of Louisiana, 1984)
State v. Tate
851 So. 2d 921 (Supreme Court of Louisiana, 2003)
State v. Smith
839 So. 2d 1 (Supreme Court of Louisiana, 2003)
State v. Mims
619 So. 2d 1059 (Supreme Court of Louisiana, 1993)
State v. Dewey
408 So. 2d 1255 (Supreme Court of Louisiana, 1982)
State v. Green
873 So. 2d 889 (Louisiana Court of Appeal, 2004)
State v. Hearold
603 So. 2d 731 (Supreme Court of Louisiana, 1992)
State v. Verrett
419 So. 2d 455 (Supreme Court of Louisiana, 1982)
State v. Bishop
835 So. 2d 434 (Supreme Court of Louisiana, 2003)
Garza v. Delta Tau Delta Fraternity Nat.
948 So. 2d 84 (Supreme Court of Louisiana, 2006)
State v. Barnett
70 So. 3d 1 (Louisiana Court of Appeal, 2011)
State v. Passaniti
144 So. 3d 1220 (Louisiana Court of Appeal, 2014)

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State of Louisiana v. Arthur Anderson, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-louisiana-v-arthur-anderson-lactapp-2024.