State of Louisiana v. Austin William Bost

CourtLouisiana Court of Appeal
DecidedApril 26, 2023
DocketKA-0022-0730
StatusUnknown

This text of State of Louisiana v. Austin William Bost (State of Louisiana v. Austin William Bost) 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. Austin William Bost, (La. Ct. App. 2023).

Opinion

STATE OF LOUISIANA COURT OF APPEAL, THIRD CIRCUIT

22-730

STATE OF LOUISIANA

VERSUS

AUSTIN WILLIAM BOST

**********

APPEAL FROM THE NINTH JUDICIAL DISTRICT COURT PARISH OF RAPIDES, NO. 352,327 HONORABLE MARY LAUVE DOGGETT, DISTRICT JUDGE

GARY J. ORTEGO JUDGE

Court composed of Sharon Darville Wilson, Gary J. Ortego, and Wilbur L. Stiles, Judges.

CONVICTIONS AND SENTENCES ARE AFFIRMED, IN PART, AND VACATED, IN PART; CASE REMANDED WITH INSTRUCTIONS. J. Phillip Terrell, Jr. District Attorney Kelvin G. Sanders Assistant District Attorney Ninth Judicial District P. O. Box 7538 Alexandria, LA 71306-7358 (318) 473-6650 COUNSEL FOR APPELLEE: State of Louisiana

Chad M. Ikerd Attorney at Law Louisiana Appellate Project P. O. Box 2125 Lafayette, LA 70502 (337) 366-8994 COUNSEL FOR DEFENDANT/APPELLANT: Austin William Bost ORTEGO, Judge.

Defendant, Austin William Bost, appeals his convictions of three counts of

indecent behavior with a juvenile under the age of thirteen, violations of La.R.S.

14:81; three counts of sexual battery of a victim under the age of thirteen, violations

of La.R.S. 14:43.1; three counts of oral sexual battery of a victim under the age of

thirteen, violations of La.R.S. 14:43.3; and three counts of aggravated crime against

nature with a child under the age of thirteen, violations of La.R.S. 14:89.1. For the

following reasons, we affirm in part, vacate in part, and remand with instructions.

FACTS AND PROCEDURAL HISTORY

On June 22, 2021, Defendant, Austin William Bost, was charged by bill of

information with three counts of indecent behavior with a juvenile under the age of

thirteen, violations of La.R.S. 14:81; three counts of sexual battery of a juvenile

under the age of thirteen, violations of La.R.S. 14:43.1; three counts of oral sexual

battery of a victim under the age of fifteen, violations of La.R.S. 14:43.3; and three

counts of aggravated crime against nature with a child under the age of thirteen,

violations of La.R.S. 14:89.1. All twelve counts of alleged sexual misconduct

involved Defendant’s four-year-old daughter, A.D. After a two-day jury trial, on

July 13, 2022, a unanimous jury found Defendant guilty of all counts. On August 18,

2022, the trial court sentenced Defendant as follows:

Indecent behavior with a juvenile under the age of thirteen (3 COUNTS) – EACH COUNT – twenty years at hard labor without benefit of probation, parole, or suspension of sentence.

Sexual battery of a child under the age of thirteen (3 COUNTS) – EACH COUNT – forty years at hard labor without benefit of probation, parole, or suspension of sentence. Also designated as a crime of violence.

Oral sexual battery of a child under the age of thirteen (3 COUNTS) – EACH COUNT – sixty years at hard labor without benefit of probation, parole, or suspension of sentence. Aggravated crime against nature with a child under the age of thirteen (3 COUNTS) – EACH COUNT – sixty years at hard labor without benefit of probation, parole, or suspension of sentence.

The trial court ordered all sentences to run concurrently with each other. On

August 26, 2022, the trial court granted Defendant’s motion for appeal.

ISSUES

On appeal, Defendant asserts five assignments of error:

1. The State failed to sufficiently prove that Austin Bost was guilty as charged.

2. Convictions for three counts of aggravated crimes against nature, which used as an essential element of the crime the same act or occurrence that was alleged in counts 1 – 9 constitute double jeopardy. Alternatively, trial counsel was ineffective for not objecting to this issue in the trial court.

3. The trial court erred in allowing the SANE nurse to testify to second- and third-hand hearsay about alleged sexual abuse of A.D. The statements were not admissible [under] La. Code Evid. art. 803(4).

4. The 60-year sentences on counts 7 – 9, Oral Sexual Battery, and counts 10 – 12, Aggravated Crimes Against Nature, are constitutionally excessive.

5. Trial counsel was ineffective for failing to file a motion to reconsider sentence. The trial court based a significant part of its decision to impose de facto life sentences on evidence of acts allegedly committed by Austin Bost when he was a child.

ERRORS PATENT

In accordance with La.Code Crim. P. art. 920, all appeals are reviewed by this

court for errors patent on the face of the record. After reviewing the record, we find

there are no errors patent. However, this court does note a conflict between the

minutes of Defendant’s sentencing and the transcript of the sentencing. Although the

minutes state the name of each offense three times, indicating three convictions for

each set of offenses, the minutes indicate that a single sentence was pronounced for

each set of convictions. The transcript of the sentencing shows the trial court

specified that the sentence it pronounced applied to “each count” of indecent 2 behavior with a juvenile, “each count” of sexual battery, “each count” of oral sexual

battery, and “each count” of aggravated crimes against nature.

“[W]hen the minutes and the transcript conflict, the transcript prevails.” State

v. Wommack, 00-137, p. 4 (La.App. 3 Cir. 6/7/00), 770 So.2d 365, 369, writ denied,

00-2051 (La. 9/21/01), 797 So.2d 62.

Therefore, the minutes of sentencing shall be corrected to clearly reflect that

the trial court imposed a sentence on each count. Accordingly, this court remands

this matter and orders the trial court to correct the minutes of sentencing to accurately

reflect that the trial court imposed the sentences on “each count.”

Additionally, we note that according to the sentencing transcript, defense

counsel asked the trial court to recommend Defendant for work release. The trial

court responded, “Um, I don’t know that that’s available on this sentence, but I’m

not gonna object to anything that the Department of Corrections finds, um,

appropriate.” However, the minutes state that the sentences were “subject to work

release.”

Therefore, this court further orders that upon remand the sentencing minutes

be amended to delete the statement “subject to work release” and to accurately reflect

the trial court’s statement that it did not know if work release was available on these

sentences, but that it will not object to anything that the Department of Corrections

finds appropriate, per the sentencing transcript.

LAW AND ANALYSIS

Elements of Each Offense

Defendant was convicted of three counts each of (1) indecent behavior with a

juvenile under the age of thirteen; (2) sexual battery of a child under the age of

thirteen; (3) oral sexual battery of a child under the age of thirteen; and (4)

aggravated crime against nature with a child under the age of thirteen. At the time 3 the offenses were committed, on or about October 29, 2020, the definition for each

offense was as follows:

Indecent behavior with juveniles, a violation of La.R.S. 14:81, provides, in

pertinent part:

A. Indecent behavior with juveniles is the commission of any of the following acts with the intention of arousing or gratifying the sexual desires of either person:

(1) Any lewd or lascivious act upon the person or in the presence of any child under the age of seventeen, where there is an age difference of greater than two years between the two persons. Lack of knowledge of the child’s age shall not be a defense[.]

Sexual battery, a violation of La.R.S. 14:43.1, provides, in pertinent part:

A.

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State of Louisiana v. Austin William Bost, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-louisiana-v-austin-william-bost-lactapp-2023.