State of Louisiana v. Braylen Marquez Leday

CourtLouisiana Court of Appeal
DecidedNovember 6, 2024
DocketKA-0024-0199
StatusUnknown

This text of State of Louisiana v. Braylen Marquez Leday (State of Louisiana v. Braylen Marquez Leday) 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. Braylen Marquez Leday, (La. Ct. App. 2024).

Opinion

STATE OF LOUISIANA COURT OF APPEAL, THIRD CIRCUIT

24-199

STATE OF LOUISIANA

VERSUS

BRAYLEN MARQUEZ LEDAY

**********

APPEAL FROM THE FOURTEENTH JUDICIAL DISTRICT COURT PARISH OF CALCASIEU, NO. 10157-22 HONORABLE ROBERT LANE WYATT, DISTRICT JUDGE

WILBUR L. STILES JUDGE

Court composed of Gary J. Ortego, Ledricka J. Thierry, and Wilbur L. Stiles, Judges.

AFFIRMED. Edward K. Bauman LA Appellate Project P. O. Box 1641 Lake Charles, LA 70602-1641 (337) 491-0570 COUNSEL FOR DEFENDANT/APPELLANT: Braylen Marquez LeDay

Hon. Stephen C. Dwight District Attorney, Fourteenth Judicial District Karen C. McClellan Assistant District Attorney John E. Turner Assistant District Attorney 901 Lakeshore Drive, Suite 800 Lake Charles, LA 70601 (337) 437-3400 COUNSEL FOR APPELLEE: State of Louisiana STILES, Judge.

A unanimous jury found Defendant, Braylen Marquez LeDay, guilty on

March 3, 2023, of first degree rape. On April 28, 2023, the trial court sentenced

Defendant to life in prison, without benefit of probation, parole, or suspension of

sentence. Defendant has appealed his conviction. We affirm Defendant’s conviction

and sentence.

PROCEDURAL HISTORY

On July 21, 2022, a grand jury indicted Defendant with one count of first

degree rape, a violation of La.R.S. 14:42. The victim, J.A., was eleven years old at

the time.1 On August 24, 2022, Defendant pled not guilty and not guilty by reason

of insanity.2

Defendant’s trial began on February 28, 2023, and ended on March 3, 2023,

with the jury unanimously finding him guilty of the first degree rape of J.A.

On April 26, 2023, the trial court held a hearing regarding Defendant’s motion

for new trial. The court not only denied Defendant’s motion, but also, per the State’s

request, revoked Defendant’s probation on an unrelated prior conviction of

obscenity.

On April 28, 2023, the trial court sentenced Defendant to life in prison at hard

labor, without benefit of probation, parole, or suspension of sentence. Defendant

filed a motion to reconsider sentence on May 31, 2023, without requesting a

contradictory hearing. That same day, the trial court denied the motion on the merits.

1 The initials of the victim are used to protect her identity as per La.R.S. 46:1844(W). 2 The minutes show that Defendant pled not guilty and not guilty by reason of mental defect. However, this was a clerical error. According to the transcript of his August 24, 2022 plea, Defendant pled not guilty and not guilty by reason of insanity. The trial court corrected this error at the beginning of his trial. Defendant timely filed the instant appeal on June 18, 2024, asserting one

assignment of error:

The evidence presented at trial, when viewed in the light most favorable to the prosecution, was insufficient to prove Braylen Leday guilty of first degree rape beyond a reasonable doubt.

ERRORS PATENT

In accordance with La.Code Crim.P. art. 920, this court reviews all appeals

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

are no errors patent.

ASSIGNMENT OF ERROR

In his sole assignment of error, Defendant contends that the evidence

presented at trial by the State was insufficient to prove beyond a reasonable doubt

all of the elements of the crime of first degree rape. Defendant has given several

reasons why he believes the State provided insufficient evidence. First, although the

jury was presented with his confession, the State presented no direct or

circumstantial evidence connecting him to any crime. Second, Defendant notes that

neither he nor the victim testified at trial. Third, Defendant claims that although male

DNA was found in the victim’s vagina one or two days after the alleged incident, the

source of the DNA was never discovered since authorities failed to take a reference

sample from Defendant. Fourth, Defendant notes that although Detective Melanie

Veillon testified that she met with the victim, the report containing the information

she gained from that interview was not entered into evidence. And lastly, Defendant

argues that his confession alone should not be sufficient to convict him.

2 Relevant Law

The analysis for insufficient-evidence claims is well 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.

This court has further stated the following regarding appellate review in cases

relying on circumstantial evidence:

When the conviction is based upon circumstantial evidence, La.R.S. 15:438 provides that the state “must exclude every reasonable hypothesis of innocence” in order to convict. State v. Camp, 446 So.2d 1207, 1209 (La.1984). “Circumstantial evidence consists of proof of collateral facts and circumstances from which elemental factors may be inferred according to reason, experience and common sense.” State v. Burns, 441 So.2d 843, 845 (La.App. 3 Cir.1983). However, La.R.S. 15:438 does not establish a stricter standard of review on appeal than the rational juror’s reasonable doubt standard. The statute serves as a guide for the jury when considering circumstantial evidence. On appeal, the issue is whether a rational trier of fact, when viewing the evidence in a light most favorable to the prosecution, could find that all reasonable hypotheses of innocence were excluded. State v. Williams, 13-497 (La.App. 3 Cir. 11/6/13), 124 So.3d 1236, writ denied, 13-2774 (La. 5/16/14), 139 So.3d 1024.

State v. Baumberger, 15-1056, pp. 10-11 (La.App. 3 Cir. 6/1/16), 200 So.3d 817,

826-27, writ denied, 16-1251 (La. 5/26/17), 221 So.3d 859, cert. denied, 583 U.S.

950, 138 S.Ct. 392 (2017).

3 First degree rape is defined in La.R.S. 14:42, which provides, in pertinent part:

A. First degree rape is a rape committed upon a person sixty-five years of age or older or where the anal, oral, or vaginal sexual intercourse is deemed to be without lawful consent of the victim because it is committed under any one or more of the following circumstances: ....

(4) When the victim is under the age of thirteen years. Lack of knowledge of the victim’s age shall not be a defense.

Evidence Presented at Defendant’s Trial

Riikeja Anderson, the victim’s mother, testified at trial that she considered

Defendant her boyfriend and that they had discussed getting married. He would

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Related

Jackson v. Virginia
443 U.S. 307 (Supreme Court, 1979)
State v. Kennerson
695 So. 2d 1367 (Louisiana Court of Appeal, 1997)
State v. Richardson
425 So. 2d 1228 (Supreme Court of Louisiana, 1983)
State v. Cruz
455 So. 2d 1351 (Supreme Court of Louisiana, 1984)
State Ex Rel. Graffagnino v. King
436 So. 2d 559 (Supreme Court of Louisiana, 1983)
State v. Duncan
420 So. 2d 1105 (Supreme Court of Louisiana, 1982)
State v. Moody
393 So. 2d 1212 (Supreme Court of Louisiana, 1981)
State v. Camp
446 So. 2d 1207 (Supreme Court of Louisiana, 1984)
State v. Williams
124 So. 3d 1236 (Louisiana Court of Appeal, 2013)
State v. Baumberger
200 So. 3d 817 (Louisiana Court of Appeal, 2016)
State v. Burns
441 So. 2d 843 (Louisiana Court of Appeal, 1983)

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State of Louisiana v. Braylen Marquez Leday, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-louisiana-v-braylen-marquez-leday-lactapp-2024.