State of Louisiana v. David Stapleton

CourtLouisiana Court of Appeal
DecidedDecember 10, 2008
DocketKA-0008-0685
StatusUnknown

This text of State of Louisiana v. David Stapleton (State of Louisiana v. David Stapleton) 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. David Stapleton, (La. Ct. App. 2008).

Opinion

NOT DESIGNATED FOR PUBLICATION

STATE OF LOUISIANA COURT OF APPEAL, THIRD CIRCUIT

08-0685

STATE OF LOUISIANA

VERSUS

DAVID STAPLETON

************

APPEAL FROM THE THIRTY-FIFTH JUDICIAL DISTRICT COURT, PARISH OF GRANT, NO. 07-169 HONORABLE ALLEN A. KRAKE, DISTRICT JUDGE

JIMMIE C. PETERS JUDGE

Court composed of Jimmie C. Peters, Marc T. Amy, and James T. Genovese, Judges.

CONVICTION AFFIRMED. SENTENCE VACATED, AND CASE REMANDED FOR RESENTENCING.

James P. Lemoine District Attorney, 35th JDC Jimmy D. White Assistant District Attorney, 35th JDC Post Office Box 309 Colfax, LA (318) 627-3205 COUNSEL FOR APPELLEE: State of Louisiana Mark O. Foster Louisiana Appellate Project Post Office Box 2057 Natchitoches, LA 71457 (318) 572-5693 COUNSEL FOR DEFENDANT/APPELLANT: David Stapleton

David L. Stapleton Caldwell Correctional Center 671 Highway 845 Grayson, LA 71435 PRO SE PETERS, J.

The State of Louisiana (state) charged the defendant, David Stapleton, by bill

of information with the offense of driving while intoxicated, fourth offense, a

violation of La.R.S. 14:98. A jury convicted him of the charge, and the trial court

sentenced him to serve thirty years at hard labor, without benefit of probation, parole,

or suspension of sentence. After the trial court rejected his motion to reconsider his

sentence, the defendant perfected this appeal, asserting three assignments of error

through his appellate counsel and three pro se assignments of error.

The defendant was initially charged by bill of information on March 21, 2007,

charging that the offense occurred February 4, 2007. A two-day trial ended on

January 15, 2008, with the jury’s verdict of guilty as charged. The trial court

sentenced the defendant on February 7, 2008, and rejected his motion for

reconsideration of sentence on March 27, 2008. On appeal, the defendant’s appellate

counsel asserted the following assignments of error:

1. The trial court erred in sentencing Mr. Stapleton to the maximum sentence of 30 years imprisonment, without benefit of probation, parole or suspension of sentence, without complying with the requirements of La.C. Cr.P. art. 894.1.

2. The maximum, 30-year sentence imposed by the trial court was cruel, unusual and excessive, in violation of Article I, § 20 of the Louisiana Constitution of 1974.

3. The trial court erred in sentencing Mr. Stapleton without him being represented by his trial counsel, in not first determining if Mr. Stapleton actually wanted to waive counsel and represent himself.

The three pro se assignments of error filed by the defendant read as follows:

1. Rather the defendant was denied rights by allowing the Hon. Judge Allen A. Krake to preside over this case

2. The mis-use of time on predicates used to enhance

1 3. Was the defendant represented by retained counsel in an appropriate manner

Considering the assignments of error asserted by the defendant’s appellate

counsel, we find merit in the third. Because disposition of that assignment of error

renders consideration of the first two assignments moot, we will address it first.

The question raised by the third assignment of error relates to the defendant’s

legal representation, or lack thereof, at the sentencing proceedings. A finding that the

defendant was not represented by counsel at the sentencing proceeding, and that he

did not waive his right to counsel or invoke the right to self-representation, would

require that his sentence be vacated.

A defendant has the right to counsel at every critical stage of the proceedings against him, including sentencing. See, State v. Kirsch, 01-1017 (La.App. 5 Cir. 3/26/02), 815 So.2d 215, 217, citing McConnell v. Rhay, 393 U.S. 2, 89 S.Ct. 32, 21 L.Ed.2d 2 (1968); La. Const. art. I, § 13. Furthermore, the constitutional right to the assistance of counsel provided by the Sixth Amendment of the United States Constitution mandates the right, unless waived, to the assistance of counsel at every critical stage of the proceedings, including an initial or deferred sentencing. See, State v. Lefeure, 01-1003 (La.App. 5 Cir. 1/15/02), 807 So.2d 922, 923-924, and cases cited therein. Sentence imposed without the presence of defendant’s attorney is illegal and of no effect, for certain vital issues cannot be raised and important rights may be lost if not raised or exercised prior to this stage of the proceedings. Id. Unless a defendant has made a knowing and intelligent waiver of his right to counsel, any sentence imposed in the absence of counsel is invalid and must be set aside. See, State v. Lefeure, at 924, and the cases cited therein.

State v. Price, 06-440, p. 3 (La.App. 5 Cir. 1/16/07), 951 So.2d 1152, 1153-54.

This court has addressed this issue as well, and in setting forth the applicable

guidelines, has stated the following:

Louisiana Constitution Article 1, Section 13 and the Sixth Amendment of the United States [Constitution] guarantee a criminal defendant the right to assistance of counsel. While a defendant may represent himself, his choice to do so must be knowingly and intelligently made and the assertion of the right to self-representation

2 must be clear and unequivocal. State v. Brown, 03-897 (La.4/12/05), 907 So.2d 1 (citing Faretta v. California, 422 U.S. 806, 95 S.Ct. 2525, 45 L.Ed.2d 562 (1975)). The supreme court reiterated that a defendant must “ask clearly and unequivocally to proceed pro se.” Id. at 22.

With regard to a defendant’s waiver of his or her right to counsel, a panel of this court has stated:

Before a defendant may waive his right to counsel, the trial court must determine whether the defendant’s waiver of counsel is intelligently and voluntarily made, and whether his assertion of his right to represent himself is clear and unequivocal. State v. Hegwood, 345 So.2d 1179 (La.1977). The determination of whether there has been an intelligent waiver of the right to counsel depends upon the facts and circumstances surrounding the case, including the background, experience, and conduct of the accused. State v. Harper, 381 So.2d 468 (La.1980). Although a defendant should be made aware of the dangers and disadvantages of self-representation, there is no particular formula which must be followed by the trial court in determining whether a defendant has validly waived his right to counsel. State v. Carpenter, 390 So.2d 1296 (La.1980). However, the record must establish that the accused knew what he was doing and that his choice was made “with eyes open.” Id. at 1298, citing Faretta v. California, 422 U.S. 806, 95 S.Ct. 2525, 45 L.Ed.2d 562 (1975).

The Third Circuit Court of Appeal has repeatedly required the trial court meet the following requirements in determining whether a defendant has validly waived his right to counsel: first, determine a defendant’s literacy, competency, understanding and volition, i.e. was defendant’s waiver of counsel made voluntarily and intelligently; and second, warn the defendant of the dangers and disadvantages of self-representation, so that the record establishes that the defendant knew what he was doing. [State v.] Mitchell, 580 So.2d 1006 [ (La.App. 3 Cir.1991), writ denied, 613 So.2d 969 (La.1993) ]; [State v.] Smith, 479 So.2d 1062 [ (La.App. 3 Cir.1985) ]; State v. Adams, 526 So.2d 867 (La.App. 3 Cir.1988); State v.

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Related

McConnell v. Rhay
393 U.S. 2 (Supreme Court, 1968)
Faretta v. California
422 U.S. 806 (Supreme Court, 1975)
Strickland v. Washington
466 U.S. 668 (Supreme Court, 1984)
State v. Brown
907 So. 2d 1 (Supreme Court of Louisiana, 2005)
State v. Whatley
858 So. 2d 751 (Louisiana Court of Appeal, 2003)
State v. Smith
479 So. 2d 1062 (Louisiana Court of Appeal, 1985)
State v. Bourgeois
541 So. 2d 926 (Louisiana Court of Appeal, 1989)
State v. Johnson
944 So. 2d 864 (Louisiana Court of Appeal, 2006)
State v. Hayes
670 So. 2d 683 (Louisiana Court of Appeal, 1996)
State v. Francis
966 So. 2d 1096 (Louisiana Court of Appeal, 2007)
State v. Adams
526 So. 2d 867 (Louisiana Court of Appeal, 1988)
State v. Kirsch
815 So. 2d 215 (Louisiana Court of Appeal, 2002)
State v. Price
951 So. 2d 1152 (Louisiana Court of Appeal, 2007)
State v. Matthis
970 So. 2d 505 (Supreme Court of Louisiana, 2007)
State v. Pendelton
696 So. 2d 144 (Louisiana Court of Appeal, 1997)
State v. Smith
952 So. 2d 1 (Louisiana Court of Appeal, 2006)
State v. Mitchell
580 So. 2d 1006 (Louisiana Court of Appeal, 1991)
State v. Sepulvado
549 So. 2d 928 (Louisiana Court of Appeal, 1989)
State v. Duplichan
945 So. 2d 170 (Louisiana Court of Appeal, 2006)
State v. Hegwood
345 So. 2d 1179 (Supreme Court of Louisiana, 1977)

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