State of Louisiana v. Demarious Hicks

CourtLouisiana Court of Appeal
DecidedMay 10, 2023
Docket55,010-KA
StatusPublished

This text of State of Louisiana v. Demarious Hicks (State of Louisiana v. Demarious Hicks) 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. Demarious Hicks, (La. Ct. App. 2023).

Opinion

Judgment rendered May 10, 2023. Application for rehearing may be filed within the delay allowed by Art. 922, La. C. Cr. P.

No. 55,010-KA

COURT OF APPEAL SECOND CIRCUIT STATE OF LOUISIANA

*****

STATE OF LOUISIANA Appellee

versus

DEMARIOUS HICKS Appellant

Appealed from the Sixth Judicial District Court for the Parish of Madison, Louisiana Trial Court No. 185,577

Honorable Laurie Reis Brister, Judge

LOUISIANA APPELLATE PROJECT Counsel for Appellant By: Peggy J. Sullivan

JAMES EDWARD PAXTON Counsel for Appellee District Attorney

ANITA TENNANT MACK EDWIN MOBERLEY BRADLEY T. SLOANE Assistant District Attorneys

Before COX, THOMPSON, and HUNTER, JJ.

HUNTER, J., concurring and assigning additional reasons. COX, J.

This criminal appeal arises from the Sixth Judicial District Court of

Madison Parish, Louisiana. The defendant, Demarious Hicks (“Hicks”) was

convicted by a jury of the second degree murder of Rodrick Bowman

(“Bowman”) and the attempted second degree murder of Trashaun Smith

(“Smith”). Hicks was sentenced to, life imprisonment at hard labor for the

death of Bowman, and 50 years at hard labor for the attempted murder of

Smith. Both sentences were to be served consecutively without benefit of

parole, probation, or suspension of sentence. For the following reasons, we

vacate Hicks’ convictions and sentences and remand the matter for a new

trial.

FACTS

On August 9, 2017, Madison Parish police officers were dispatched to

the Madison and Wyche Apartments in Tallulah, Louisiana, in response to a

shooting. Evidence at trial established that when officers arrived at the

apartment complexes, they discovered that two men, Bowman and Smith,

had been shot by a single bullet. Officers learned that Bowman sustained a

fatal gunshot wound in the back of his head and that the same bullet passed

through Bowman and struck Smith in the chest. Smith was later transported

to a hospital in Mississippi with life-threatening injuries. Following a series

of interviews with potential witnesses, officers arrested Hicks on August 10,

2017.

On October 18, 2017, the State filed a bill of indictment, charging

Hicks with the second degree murder of Bowman and attempted second

degree murder of Smith, and a grand jury returned a true bill as to both

counts. The following day, Hicks was arraigned and entered a plea of not guilty on both counts. Following a litany of pretrial motions, a jury trial

commenced on November 15, 2021.

After closing arguments and jury instructions, Hicks was found guilty

as charged. Neither the State nor defense counsel requested the jury be

polled. On January 13, 2022, Hicks filed a motion for new trial and post-

verdict judgment of acquittal, arguing insufficiency of evidence; namely,

that the credibility of certain witnesses cast doubt as to Hicks’ guilt. Both

motions were denied prior to sentencing and defense counsel waived all

sentencing delays. At sentencing, the trial court noted that Hicks made

several derogatory remarks after the verdict was rendered, following the

victim impact statement, and consistently made remarks after the trial court

recited its consideration of the 894.1(b) factors. Thereafter, the trial court

sentenced Hicks to life imprisonment at hard labor for the death of Bowman,

and 50 years at hard labor for the attempted murder of Smith. Both

sentences were to be served consecutively without benefit of parole,

probation, or suspension of sentence.

Hicks now appeals his conviction and sentence.

DISCUSSION

As a precursor to his five assignments of error, Hicks argues that the

trial court erred in instructing the jury that 10 of the 12 jurors were needed to

reach a verdict and that his conviction should be set aside and remanded for

a new trial. In citing Ramos v. Louisiana, 590 U.S. - - - -, 140 S. Ct. 1390,

206 L. Ed. 2d 583 (2020), Hicks notes that because his trial occurred in

November 2021, after Ramos, supra was rendered, a unanimous jury verdict

was required to convict him. We agree.

2 In Ramos, supra, the United States Supreme Court expressly held that

the right to a jury trial under the Sixth Amendment to the U.S. Constitution,

incorporated against the states by way of the Fourteenth Amendment to the

U.S. Constitution, requires a unanimous verdict to convict a defendant of a

serious offense in both federal and state courts. The Court concluded:

Wherever we might look to determine what the term “trial by an impartial jury trial” meant at the time of the Sixth Amendment’s adoption–whether it’s the common law, state practices in the founding era, or opinions and treatises written soon afterward–the answer is unmistakable. A jury must reach a unanimous verdict in order to convict.

Ramos, supra, at 1395.

The Louisiana Supreme Court subsequently concluded that a less than

unanimous jury verdict on a matter of direct appeal is error patent. State v.

Richardson, 20-00175 (La. 6/3/20), 296 So. 3d 1050, citing Griffith v.

Kentucky, 479 U.S. 314, at 328, 107 S. Ct. 708, at 716, 93 L.Ed.2d 649

(1987).

Although the offense in the present matter occurred in 2017, trial did

not commence until November 2021, at which time, Ramos, supra, had long

since been rendered and positioned as the governing precedent over verdicts

in jury trials. Therefore, the State’s assertion that La. C. Cr. P. art. 782 is

applicable, is without merit. Furthermore, Hicks argues that the trial court

erred in instructing the jury that only 10 jurors were needed to reach a

verdict. In citing Sullivan v. Louisiana, 508 U.S. 275, 113 S.Ct. 2078, 124

L.Ed.2d 182 (1993), in which the Louisiana Supreme Court held that an

erroneous jury instruction as to reasonable doubt was considered a structural

error, Hicks similarly contends that the jury instruction in this case was a

3 structural error that warrants his convictions and sentences to be vacated and

remanded for a new trial.

In State v. Langley, 06-1041 (La. 5/22/07), 958 So. 2d 1160, 1164,

cert. denied, 552 U.S. 1007, 128 S.Ct. 493, 169 L.Ed. 2d 368 (2007), the

Louisiana Supreme Court recognized a distinction between “trial errors,”

which may be reviewed for harmless error, and “structural errors,” which are

not subject to harmless error analysis. Structural errors deprive a defendant

of basic protections without which a criminal trial cannot reliably serve its

function to determine guilt or innocence. State v. Chapman, 54,590 (La.

App. 2 Cir. 11/16/22), 351 So. 3d 876. However, structural defects occur in

only “a very limited class of cases,” which include: (1) the total deprivation

of the right to counsel; (2) a biased trial judge; (3) unlawful exclusion of

grand jurors of defendant’s race; (4) denial of self-representation at trial; (5)

denial of a public trial; and (6) a defective reasonable doubt instruction.

Langley, supra.

This issue is not one of first impression, as courts have previously

addressed structural errors as it relates to an error in jury instructions

concerning unanimous jury verdicts.

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Related

Drope v. Missouri
420 U.S. 162 (Supreme Court, 1975)
Estelle v. Williams
425 U.S. 501 (Supreme Court, 1976)
Griffith v. Kentucky
479 U.S. 314 (Supreme Court, 1987)
Sullivan v. Louisiana
508 U.S. 275 (Supreme Court, 1993)
State v. Butler
714 So. 2d 877 (Louisiana Court of Appeal, 1998)
Louisiana v. Langley
128 S. Ct. 493 (Supreme Court, 2007)
State v. Giordano
249 So. 2d 558 (Supreme Court of Louisiana, 1971)
State v. Neslo
433 So. 2d 73 (Supreme Court of Louisiana, 1983)
State v. Langley
958 So. 2d 1160 (Supreme Court of Louisiana, 2007)
State v. Edwards
750 So. 2d 893 (Supreme Court of Louisiana, 1999)
State v. Reed
712 So. 2d 572 (Louisiana Court of Appeal, 1998)
State v. Flowers
204 So. 3d 271 (Louisiana Court of Appeal, 2016)
Ramos v. Louisiana
140 S. Ct. 1390 (Supreme Court, 2020)
Coulibaly v. Immigration & Naturalization Service
528 U.S. 1027 (Supreme Court, 1999)

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State of Louisiana v. Demarious Hicks, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-louisiana-v-demarious-hicks-lactapp-2023.