State of Louisiana v. Christopher O. James

CourtLouisiana Court of Appeal
DecidedApril 5, 2017
DocketKA-0016-0522
StatusUnknown

This text of State of Louisiana v. Christopher O. James (State of Louisiana v. Christopher O. James) 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 O. James, (La. Ct. App. 2017).

Opinion

STATE OF LOUISIANA COURT OF APPEAL, THIRD CIRCUIT

16-522

STATE OF LOUISIANA

VERSUS

CHRISTOPHER O. JAMES

**********

APPEAL FROM THE THIRTY-THIRD JUDICIAL DISTRICT COURT PARISH OF ALLEN, NO. CR-2015-2085 HONORABLE ERROL DAVID DESHOTELS, JR., DISTRICT JUDGE

ULYSSES GENE THIBODEAUX CHIEF JUDGE

Court composed of Ulysses Gene Thibodeaux, Chief Judge, Marc T. Amy, and Phyllis M. Keaty, Judges.

AFFIRMED IN PART; REVERSED IN PART AND REMANDED FOR RESENTENCING.

Paula Corley Marx Louisiana Appellate Project P. O. Box 80006 Lafayette, LA 70598-0006 Telephone: (337) 991-9757 COUNSEL FOR: Defendant/Appellant - Christopher O. James

Herbert Todd Nesom District Attorney – 33rd Judicial District Court Steven Sumbler Assistant District Attorney – 33rd Judicial District Court P. O. Box 839 Oberlin, LA 70655 Telephone: (337) 639-2641 COUNSEL FOR: Plaintiff/Appellee - State of Louisiana THIBODEAUX, Chief Judge.

Christopher James was arrested after he removed a bag from his

pocket that contained five rocks of crack cocaine and threw it onto the front

driver’s seat. He did so as the arresting officer was conducting a pat-down

subsequent to a traffic stop. He was charged with possession of cocaine with intent

to distribute and obstruction of justice. A jury found him guilty of both charges.

The trial judge sentenced him to serve concurrent terms of ten years for the drug

charge and five years for obstruction of justice. Mr. James now appeals the

convictions. For the reasons that follow, we affirm the conviction and sentence for

obstruction of justice, but reverse the possession of cocaine with intent to distribute

conviction and enter a judgment of guilty on the lesser charge of possession of

cocaine. We remand the matter for resentencing on that conviction.

I.

ISSUES

We must decide:

1. whether there was sufficient evidence to support a guilty verdict of possession of cocaine with intent to distribute;

2. whether there is sufficient evidence to support a guilty verdict of obstruction of justice;

3. whether the trial court deprived Mr. James of his right to present a defense when it denied his motion for a continuance to conduct additional discovery;

4. whether the trial court erred in denying Mr. James’s motion for a mistrial;

5. whether prospective jurors were struck because of their race (Black), in violation of Batson v. Kentucky, 476 U.S. 79 (1986), resulting in an all-white jury; and 6. whether the obstruction of justice verdict form was defective.

II.

FACTS AND PROCEDURAL HISTORY

Mr. James was pulled over for driving without a valid driver’s license.

Before the traffic stop, Officer Brandon Johnson was alerted via a narcotics tip that

Mr. James was selling crack cocaine. Officer Johnson attested that he previously

cited Mr. James for operating a motor vehicle without a valid driver’s license.

Officer Johnson confirmed through the Louisiana traffic database that Mr. James

still did not have a valid license and a traffic stop followed. Officer Johnson

instructed Mr. James to get out of the car and to place his hands on the top of the

car.

During the subsequent pat-down, Mr. James removed contents from

his pocket and threw them through the car’s open window. The contents included

a small bag containing .77 grams of crack cocaine (five rocks). Mr. James’s

passenger, Kennon Richard, grabbed the bag and attempted to hide it between the

armrest and the passenger’s seat. Mr. James and Mr. Richard were both placed

under arrest. The bag containing the crack cocaine was in plain view and was

confiscated by Officer Johnson. Mr. James was charged by bill of information

with possession of cocaine with intent to distribute and obstruction of justice.

On the morning of trial, the trial court heard and denied Mr. James’s

oral motion to continue the trial. During voir dire, the State exercised peremptory

challenges to strike six minority persons from the jury, resulting in Mr. James

being tried by an all-white jury. The jury found Mr. James guilty on both charges.

2 III.

ERRORS PATENT

In accordance with La.Code Crim.P. art. 920, we review all appeals

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

error patent.

We note that Mr. James was advised incorrectly at sentencing that he

had two years from that date to file an application for post-conviction relief.

However, La.Code Crim.P. art. 930.8 provides that a defendant has two years after

the conviction and sentence become final to seek post-conviction relief. Thus, the

trial court is directed to correctly inform Mr. James of the provisions of La.Code

Crim.P. art. 930.8 by sending appropriate written notice to him within ten days of

the rendition of the opinion and to file written proof in the record that he received

the notice. State v. Baylor, 08-141 (La.App. 3 Cir. 11/26/08), 998 So.2d 800, writ

denied, 09-275 (La. 11/20/09), 25 So.3d 795.

IV.

LAW AND DISCUSSION

A. Whether there was sufficient evidence to support a guilty verdict of possession of cocaine with intent to distribute.

Mr. James first argues that there is insufficient evidence to support a

guilty verdict of possession of cocaine with the intent to distribute.1 He notes that:

(1) the cocaine weighed less than a gram; (2) the rocks were all in one bag; and (3)

he was arrested with cigarettes, a lighter, and only five dollars, all of which

1 The knowing or intentional distribution of a Schedule II controlled dangerous substance (CDS) is a felony offense. La.R.S. 40:967. Crack cocaine is a Schedule II CDS. La.R.S. 40:964, Schedule II, (A)(4). “Distribution” includes the physical delivery or administration of a substance. La.R.S. 40:961(14).

3 indicate his intention to use but not distribute cocaine. In doing so, Mr. James

admits that he possessed cocaine but that there is insufficient evidence to prove his

intent to distribute the cocaine.

The State contends that his intention to distribute is inferred from the

circumstances surrounding his arrest. The State posits that: (1) the cigarettes were

not hand rolled, which would ordinarily be used to smoke crack cocaine; (2) the

cocaine was packaged in a baggie, which indicated an intent to distribute because

crack users typically receive their crack unbound; and (3) there was no evidence

that Mr. James was a cocaine user.

The standard of review in a sufficiency of the evidence claim is

“whether, viewing the evidence in the light most favorable to the prosecution, any

rational trier of fact could have found proof beyond a reasonable doubt of each of

the essential elements of the crime charged.” State v. Leger, 05-11, p. 91 (La.

7/10/06), 936 So.2d 108, 170, cert. denied, 549 U.S. 1221, 127 S.Ct. 1279 (2007)

(citing Jackson v. Virginia, 443 U.S. 307, 99 S.Ct. 2781 (1979); State v. Captville,

448 So.2d 676, 678 (La.1984)).

The Jackson standard of review is now legislatively embodied in

La.Code Crim.P. art. 821. It does not allow the appellate court “to substitute its

own appreciation of the evidence for that of the fact-finder.” State v. Pigford,

05-477, p. 6 (La. 2/22/06), 922 So.2d 517, 521 (citing State v. Robertson, 96-1048

(La. 10/4/96), 680 So.2d 1165; State v.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

McDaniel v. Brown
558 U.S. 120 (Supreme Court, 2010)
Jackson v. Virginia
443 U.S. 307 (Supreme Court, 1979)
Batson v. Kentucky
476 U.S. 79 (Supreme Court, 1986)
Hernandez v. New York
500 U.S. 352 (Supreme Court, 1991)
State v. Mussall
523 So. 2d 1305 (Supreme Court of Louisiana, 1988)
State v. Belgard
410 So. 2d 720 (Supreme Court of Louisiana, 1982)
State v. Durgan
931 So. 2d 1182 (Louisiana Court of Appeal, 2006)
State v. Captville
448 So. 2d 676 (Supreme Court of Louisiana, 1984)
State v. Gaskin
412 So. 2d 1007 (Supreme Court of Louisiana, 1982)
State v. Smith
661 So. 2d 442 (Supreme Court of Louisiana, 1995)
State v. Leger
936 So. 2d 108 (Supreme Court of Louisiana, 2006)
State v. Tilley
767 So. 2d 6 (Supreme Court of Louisiana, 2000)
State v. House
325 So. 2d 222 (Supreme Court of Louisiana, 1976)
State v. Collier
553 So. 2d 815 (Supreme Court of Louisiana, 1989)
State v. Hobley
752 So. 2d 771 (Supreme Court of Louisiana, 1999)
State v. Lubrano
563 So. 2d 847 (Supreme Court of Louisiana, 1990)
State v. Pigford
922 So. 2d 517 (Supreme Court of Louisiana, 2006)
State v. Newton
973 So. 2d 916 (Louisiana Court of Appeal, 2007)
State v. Tyler
723 So. 2d 939 (Supreme Court of Louisiana, 1998)
State v. Green
655 So. 2d 272 (Supreme Court of Louisiana, 1995)

Cite This Page — Counsel Stack

Bluebook (online)
State of Louisiana v. Christopher O. James, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-louisiana-v-christopher-o-james-lactapp-2017.