State of Louisiana v. Broderick Crawford

CourtLouisiana Court of Appeal
DecidedMay 25, 2022
Docket54,391-KA
StatusPublished

This text of State of Louisiana v. Broderick Crawford (State of Louisiana v. Broderick Crawford) 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. Broderick Crawford, (La. Ct. App. 2022).

Opinion

Judgment rendered May 25, 2022. Application for rehearing may be filed within the delay allowed by Art. 922, La. C. Cr. P.

No. 54,391-KA

COURT OF APPEAL SECOND CIRCUIT STATE OF LOUISIANA

*****

STATE OF LOUISIANA Appellee

versus

BRODERICK CRAWFORD Appellant

Appealed from the First Judicial District Court for the Parish of Caddo, Louisiana Trial Court No. 370,573

Honorable Christopher Victory, Judge

LOUISIANA APPELLANT PROJECT Counsel for Appellant By: Douglas Lee Harville

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

REBECCA ARMAND EDWARDS KODIE K. SMITH Assistant District Attorneys

Before MOORE, THOMPSON, and HUNTER, JJ. THOMPSON, J.

A 36-year old man was convicted by a unanimous jury of first degree

rape for forcing his girlfriend’s 10-year-old daughter to perform oral sex on

him. He was sentenced to the mandatory life in prison at hard labor, without

the possibility of parole, probation, or suspension of sentence. He now

appeals his conviction and sentence, arguing that the State failed to

sufficiently prove that he was guilty of first degree rape because of

inconsistencies in the victim’s and a child witness’ testimony, as well as

possible coaching of the victim’s testimony. We affirm his conviction and

sentence.

FACTS

Broderick Crawford (“Crawford”), was in a long-term relationship

with S.K., with whom he shared two children. S.K. also had four other

children, including the victim, 10-year-old E.Y., who lived with her in her

home. On the night of July 21, 2019, Crawford was visiting the home of

S.K., although he did not consistently reside there. S.K. left Crawford and

her children at home while she went out with a cousin. When S.K. left the

home that evening, her daughter, 10-year-old E.Y., another daughter, 13-

year-old K.K., and their other siblings were watching TV in the bedroom.

When S.K. later returned home, she received a text message from her

daughter K.K. about E.Y. crying. S.K. went to check on E.Y., and when

asked why she was crying, E.Y. told her mother that Crawford “made her

suck his weenie.” S.K. confronted Crawford, wielding a broom. When S.K.

asked Crawford what he did to her child, not specifying which child,

Crawford immediately referred to E.Y. and said “you better tell the truth, you `bout to mess my life up.” S.K. left the home with her children and

went to Crawford’s mother’s house nearby and contacted the police.

The next day, July 22, 2019, E.Y. was taken by her mother for a

medical examination and then a forensic interview by law enforcement

investigators. During that interview, E.Y. disclosed that her stepdad put his

privates in her mouth the night before when her mother was gone to her

cousin’s house. K.K., E.Y.’s sibling, also provided a forensic interview.

K.K. stated she was being interviewed because her stepfather “sexually

assaulted” her sister. K.K. stated that she did not see anything and remained

in the other room watching TV.

On August 9, 2019, Alex Person, the director of education and a

forensic interviewer at the Gingerbread House Children’s Advocacy Center,

interviewed E.Y. and her siblings. E.Y. stated during this interview that the

reason she was being interviewed was because of her “sexual assault.” E.Y.

provided the same consistent description of the incident – that Crawford

forced her to perform oral sex on him. Crawford was charged with first

degree rape as provided in La. R.S. 14:42(A)(4) as the victim was under 13

years of age.

A jury trial was held in Caddo Parish, Louisiana, on May 20 and May

21, 2021. E.Y.’s Gingerbread House interview was introduced as evidence

and played for the jury during the trial. During her testimony, E.Y.

confirmed that the contents of her Gingerbread House interview were true.

E.Y. also testified that her sister, K.K., told E.Y. that she saw Crawford

pushing E.Y.’s head down during the incident. At trial, on cross-

examination, K.K. testified that she saw E.Y. coming and going between the

bedroom and the living room. 2 At trial, S.K. testified that Crawford texted her, admitting what he did

to E.Y. Specifically, the text exchange between S.K. and Crawford provided:

S.K.: “U made my baby put ur dick in her mouth,”

Crawford: “I will forever be sorry I hate myself for doing that did [sic].” […]“I’m sorry, tell her I’m sorry for that. I failed y’all.”

Crawford’s texts also referenced sexual abuse from his own childhood

and an acknowledgment that his behavior was wrong. Crawford testified at

trial in his own defense and stated that he was referring to himself, not E.Y.,

in the texts he sent to S.K. Crawford claimed that he was depressed and

S.K. manipulated him into believing E.Y.’s accusations against him.

Based on the evidence and testimony adduced at trial, the jury

returned a unanimous verdict of guilty as charged of first degree rape, victim

under the age of 13 years. In accordance with La. R.S. 14:41(D)(1), the trial

court imposed the mandatory sentence of life imprisonment at hard labor,

without benefit of probation, parole, or suspension of sentence. This appeal

followed.

DISCUSSION

In his single assignment of error, Crawford appeals his conviction,

asserting insufficient evidence, specifically:

Assignment of Error: Whether there was insufficient evidence to prove beyond a reasonable doubt that Broderick Crawford raped E.Y.

The proper test for determining a claim of insufficiency of evidence in

a criminal case is whether, on the entire record, a rational trier of fact could

find the defendant guilty beyond a reasonable doubt. Jackson v. Virginia,

443 U.S. 307, 99 S. Ct. 2781, 61 L. Ed. 2d 560 (1979); State v. Tate, 01-

1658 (La. 5/20/03), 851 So. 2d 921, cert. denied, 541 U.S. 905, 124 S. Ct.

3 1604, 158 L. Ed. 2d 248 (2004), State v. Holder, 50,171 (La. App. 2 Cir.

12/9/15), 181 So. 3d 918, 929, writ denied, 16-0092 (La. 12/16/16), 211 So.

3d 1166. This standard, now legislatively embodied in La. C. Cr. P. art. 821,

does not provide the appellate court with a vehicle to substitute its own

appreciation of the evidence for that of the fact finder. State v. Steines,

51,698 (La. App. 2 Cir. 11/15/17), 245 So. 3d 224, writ denied, 17-2174 (La.

10/8/18), 253 So. 3d 797.

The appellate court does not assess the credibility of witnesses or

reweigh the evidence. State v. Smith, 94-3116 (La. 10/16/95), 661 So. 2d

442; State v. Dale, 50,195 (La. App. 2 Cir. 11/18/15), 180 So. 3d 528, writ

denied, 15-2291 (La. 4/4/16), 190 So. 3d 1203. A reviewing court affords

great deference to a trial court’s decision to accept or reject the testimony of

a witness in whole or in part. State v. Steines, supra. Thus, this court is

charged with examining the evidence in the light most favorable to the

prosecution and determining whether any rational trier of fact could have

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Related

Jackson v. Virginia
443 U.S. 307 (Supreme Court, 1979)
Yarborough v. Gentry
540 U.S. 1 (Supreme Court, 2003)
Robertson v. Casual Corner Group, Inc
541 U.S. 905 (Supreme Court, 2004)
State v. Smith
661 So. 2d 442 (Supreme Court of Louisiana, 1995)
State v. Jones
733 So. 2d 127 (Louisiana Court of Appeal, 1999)
State v. Tate
851 So. 2d 921 (Supreme Court of Louisiana, 2003)
State v. Dale
180 So. 3d 528 (Louisiana Court of Appeal, 2015)
State v. Holder
181 So. 3d 918 (Louisiana Court of Appeal, 2015)
State v. Steines
245 So. 3d 224 (Louisiana Court of Appeal, 2017)

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State of Louisiana v. Broderick Crawford, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-louisiana-v-broderick-crawford-lactapp-2022.