State of Louisiana v. Christopher Gatson

CourtLouisiana Court of Appeal
DecidedSeptember 27, 2023
DocketKA-0023-0123
StatusUnknown

This text of State of Louisiana v. Christopher Gatson (State of Louisiana v. Christopher Gatson) 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. Christopher Gatson, (La. Ct. App. 2023).

Opinion

NOT DESIGNATED FOR PUBLICATION

STATE OF LOUISIANA COURT OF APPEAL, THIRD CIRCUIT

23-123

STATE OF LOUISIANA

VERSUS

CHRISTOPHER GATSON

**********

APPEAL FROM THE NINTH JUDICIAL DISTRICT COURT PARISH OF RAPIDES, NO. 348,420 HONORABLE WILLIAM GREGORY BEARD, DISTRICT JUDGE

ELIZABETH A. PICKETT CHIEF JUDGE

Court composed of Elizabeth A. Pickett, Ledricka J. Thierry, and Wilbur L. Stiles, Judges.

AFFIRMED.

G. Paul Marx Louisiana Appellate Project PO Box 82389 Lafayette, LA 70598-2389 (337) 237-2537 COUNSEL FOR DEFENDANT- APPELLANT: Christopher Gatson Phillip Terrell, Jr. District Attorney, Ninth Judicial District Kenneth A. Doggett, Jr. Assistant District Attorney P. O. Box 7358 Alexandria, La 71306-7358 (318) 473-6650 COUNSEL FOR APPELLEE: State of Louisiana PICKETT, Chief Judge.

FACTS

The defendant, Christopher Gatson, is accused of having sexual intercourse

with the victim on several occasions between January of 2019 and October of

2019. The victim turned thirteen in August of 2019. According to the victim, who

referred to the defendant as her “god-daddy,” one of the incidents of sexual

intercourse occurred before her thirteenth birthday.

On September 29, 2020, the defendant was charged by grand jury indictment

with one count of first degree rape, a violation of La.R.S. 14:42, and one count of

carnal knowledge of a juvenile, a violation of La.R.S. 14:80. On September 23,

2022, after a four-day jury trial, the defendant was found guilty of both counts.

Thereafter, on November 14, 2022, a motion for post-verdict judgment of acquittal

was denied by the trial court. After the defendant waived the sentencing delay

required by La.Code Crim.P. art. 873, the trial court gave its reasons for sentencing

and sentenced the defendant to life imprisonment at hard labor, without benefit of

parole, probation, or suspension of sentence for first degree rape and ten years at

hard labor for carnal knowledge of a juvenile. The trial court ordered the sentences

to run consecutively. The trial court also designated the first degree rape

conviction as a crime of violence and provided written notification of the

defendant’s sex-offender registration requirements.

Pursuant to the defendant’s motion for appeal, on December 7, 2022, the

trial court granted an appeal of the defendant’s conviction and sentence.

Thereafter, on December 12, 2022, the defendant filed a Motion for

Reconsideration of Sentence, which was denied by the trial court that same date.

On appeal, the defendant alleges three assignments of error. ASSIGNMENTS OF ERROR

1. The evidence was insufficient to prove the age of the victim at the time of the offense: THE STATE DID NOT PROVE BEYOND A REASONABLE DOUBT THAT INTERCOURSE OCCURRED BEFORE THE THIRTEENTH BIRTHDAY OF J.B. ABSENT THAT PROOF, THE HIGHEST GRADE OFFENSE IN THIS CASE IS CARNAL KNOWLEDGE.

2. It was error to restrict cross examination of the credibility of the victim under the Rape Shield Statute: THE TRIAL COURT ERRED IN RULING THAT THE ALLEGED VICTIM COULD NOT BE CROSS EXAMINED ON PRIOR STATEMENTS TO IMPEACH HER CREDIBILITY UNDER THE “RAPE SHIELD” PROVISIONS OF CODE OF EVIDENCE ARTICLE 412.

3. Due process was denied to Christopher Gatson when the court refused to order discovery before indictment. THE TRIAL COURT ERRED IN DENYING DISCOVERY BASED ON “NO BILL OF INFORMATION FILED”, WHERE CHRISTOPHER GATSON WAS INCARCERATED AND UNABLE TO POST BOND. DEFENDANT[’S] RIGHTS TO CONFRONTATION AND DUE PROCESS WERE APPLICABLE IMMEDIATELY BECAUSE OF LOSS OF LIBERTY.

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 no errors patent.

ASSIGNMENT OF ERROR NUMBER ONE

The defendant contends the State failed to prove beyond a reasonable doubt

that intercourse occurred between the defendant and the victim (J.B.) prior to the

victim’s thirteenth birthday.1 Absent such proof, the defendant argues the evidence

was sufficient to prove carnal knowledge of a juvenile, not first degree rape. For

the reasons discussed, this assignment lacks merit.

1 Initials of the victim are used pursuant to La.R.S. 46:1844(W)(1)(a). 2 Standard of Review

In reviewing the sufficiency of evidence, this court has set forth the standard

of review as follows:

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 (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 credibilities of the witnesses, and therefore, the appellate court should not second guess the credibility determinations of the trier of fact beyond the sufficiency evaluations under the Jackson standard of review. See Graffagnino, 436 So.2d at 563, citing State v. Richardson, 425 So.2d 1228 (La.1983). To obtain a conviction, the elements of the crime must be proven beyond a reasonable doubt.

State v. Thacker, 13-516, p. 5 (La.App. 3 Cir. 1/28/15), 157 So.3d 798, 804

(quoting State v. Freeman, 01-997, pp. 2-3 (La.App. 3 Cir. 12/12/01), 801 So.2d

578, 580).

Evidence Presented at Trial

The first piece of evidence introduced at trial was S-1, the victim’s

Children’s Advocacy Center (CAC) interview. A transcript of the interview was

introduced into the record as S-2 and was made available for the jury to read while

the interview was played. The trial court agreed that it would instruct the jurors

that if there was any discrepancy between the transcript and the video, the video

would prevail.

The state introduced as S-3 a complete copy of the victim’s medical records.

A “slimmed down” version of the medical records was also introduced as S-4 and

included only those records related to the matter at issue.

The first witness to testify was Heather Ducote, a school-based nurse

practitioner for Rapides Parish. Ms. Ducote worked at Alexandria Middle Magnet 3 and performed wellness checkups on the students that had Medicaid. According to

Ms. Ducote, these types of checkups were called “KIDMED” visits. During Ms.

Ducote’s wellness visit with the victim, the following occurred:

A. I seen [sic] her for the first time. She just came in for a wellness visit. And with all my kids I ask them, you know, do they feel safe at home, and normal things like they [sic] brush their teeth, just the random questions we ask. And I also ask if they’re sexually active, and most the [sic] children say no. She did tell me no that day, and she did, was not sexually active. So I didn’t think nothing else of it. I usually go by what they say, but the test results came back two days later that she was positive for chlamydia. That’s a red flag, especially with her age. So what we do is we, we treat.

According to Ms. Ducote, chlamydia is one of the most common sexually

transmitted diseases (STDs).

Ms. Ducote identified S-3 as a complete set of the victim’s medical records.

According to the records, Ms. Ducote testified, the victim’s date of birth was

August 25, 2006. During Ms.

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Related

Jackson v. Virginia
443 U.S. 307 (Supreme Court, 1979)
Apprendi v. New Jersey
530 U.S. 466 (Supreme Court, 2000)
State v. Rives
407 So. 2d 1195 (Supreme Court of Louisiana, 1981)
State v. Mitchell
412 So. 2d 1042 (Supreme Court of Louisiana, 1982)
State v. Richardson
425 So. 2d 1228 (Supreme Court of Louisiana, 1983)
State v. Smith
743 So. 2d 199 (Supreme Court of Louisiana, 1999)
State v. Ford
682 So. 2d 847 (Louisiana Court of Appeal, 1996)
State v. Vaccaro
411 So. 2d 415 (Supreme Court of Louisiana, 1982)
State v. Ponsell
766 So. 2d 678 (Louisiana Court of Appeal, 2000)
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. Freeman
801 So. 2d 578 (Louisiana Court of Appeal, 2001)
State v. Roussel
381 So. 2d 796 (Supreme Court of Louisiana, 1980)
State v. Lilly
111 So. 3d 45 (Louisiana Court of Appeal, 2012)
State v. Hypolite
139 So. 3d 687 (Louisiana Court of Appeal, 2014)
State v. Thacker
157 So. 3d 798 (Louisiana Court of Appeal, 2015)
State v. Carter
84 So. 3d 499 (Supreme Court of Louisiana, 2012)
Day v. Allen
129 So. 260 (Louisiana Court of Appeal, 1930)
State v. Parkerson
530 So. 2d 94 (Supreme Court of Louisiana, 1988)

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State of Louisiana v. Christopher Gatson, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-louisiana-v-christopher-gatson-lactapp-2023.