State of Louisiana v. Dolan McGinnis

CourtLouisiana Court of Appeal
DecidedMarch 11, 2020
Docket2019-KA-0381
StatusPublished

This text of State of Louisiana v. Dolan McGinnis (State of Louisiana v. Dolan McGinnis) 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. Dolan McGinnis, (La. Ct. App. 2020).

Opinion

STATE OF LOUISIANA * NO. 2019-KA-0381

VERSUS * COURT OF APPEAL DOLAN MCGINNIS * FOURTH CIRCUIT * STATE OF LOUISIANA *******

APPEAL FROM CRIMINAL DISTRICT COURT ORLEANS PARISH NO. 540-937, SECTION “B” Honorable Tracey Flemings-Davillier, Judge ****** Judge Terri F. Love ****** (Court composed of Judge Terri F. Love, Judge Daniel L. Dysart, Judge Paula A. Brown)

Leon Cannizzaro District Attorney Irena Zajickova Assistant District Attorney DISTRICT ATTORNEY'S OFFICE ORLEANS PARISH 619 S. White Street New Orleans, LA 70119

COUNSEL FOR STATE OF LOUISIANA/APPELLEE

Bruce G. Whittaker LOUISIANA APPELLATE PROJECT 1215 Prytania Street, Suite 332 New Orleans, LA 70130-4357

COUNSEL FOR DEFENDANT/APPELLANT

CONVICTIONS AFFIRMED; SENTENCE VACATED; REMANDED FOR RESENTENCING MARCH 11, 2020 Defendant Dolan McGinnis (“Mr. McGinnis”) seeks appellate review of his

convictions and sentences for domestic abuse battery by strangulation, domestic

abuse battery, and false imprisonment. On appellate review, we find the evidence

presented at trial was sufficient to establish Mr. McGinnis’ guilt on all charges.

However, following the trial court’s denial of Mr. McGinnis’ supplemental motion

for new trial, the trial court failed to observe the 24-hour time delay before

sentencing Mr. McGinnis. Therefore, we affirm Mr. McGinnis’ convictions,

vacate his sentence, and remand the matter for resentencing.

PROCEDURAL HISTORY AND FACTUAL BACKGROUND

Rhonda Mitchell testified at trial that in 2017 she was engaged to Mr.

McGinnis, and they lived together when the domestic abuse transpired. She

testified as to two specific incidents of abuse that occurred in November and

December 2017.

In late November 2017, Mr. McGinnis picked up Ms. Mitchell from work,

when the two got into an argument in the car. Mr. McGinnis began hitting her on

1 the left side of her face multiple times. Ms. Mitchell stated that as Mr. McGinnis’

vehicle slowed down as it neared a drug store, she jumped out of the car and took

refuge in the store. Once inside, she used a phone to call her friend Demetrice

Hutson (“Ms. Hutson”) to pick her up from the store.

Ms. Hutson testified that she and the victim Ms. Mitchell were best friends

and that at the time of the November incident she was living with Ms. Mitchell and

Mr. McGinnis. She recalled that she was at home with her daughter when she

received Ms. Mitchell’s call. She stated that when she arrived and saw the victim,

she could see Ms. Mitchell was hurt and asked her what happened. Ms. Mitchell

informed her that Mr. McGinnis had hit her and that she jumped out of the car and

scraped her face on the pavement.

At some point after Ms. Hutson retrieved Ms. Mitchell from the drug store,

Ms. Mitchell called 911. She identified herself as the victim of physical domestic

abuse and that Mr. McGinnis was the perpetrator. She explained that she did not

need medical attention but wanted a police officer to meet her at her home to

ensure her safety. When no police unit was forthcoming, Ms. Mitchell grew

frustrated and upset. Ms. Mitchell called a second time and explained that she was

sitting in her car outside her home, still waiting on the police. Eventually, Ms.

Mitchell and Ms. Hutson went to the police station where she reported the incident

to officers, explaining that they wanted officers to accompany them to the house to

ensure their safety while they pack their belongings so that they could stay

elsewhere. At trial, Ms. Hutson identified photographs that depicted Ms.

2 Mitchell’s appearance following the November incident.

Officer Marion Mickey (“Officer Mickey”) of the New Orleans Police

Department testified that she investigated both instances of domestic abuse

reported by Ms. Mitchell. She stated that in November 2017 she, along with other

officers, accompanied Ms. Mitchell to her residence to make sure the perpetrator of

the abuse was not at the home. Body camera footage from the November

investigation was played for the jury. The footage showed Ms. Mitchell sitting in

her car outside of the police station explaining to officers she needed a police

escort to her home to pack her belongings and leave the vicinity. Ms. Mitchell

showed the investigating officers the injuries she suffered when she jumped out of

the moving vehicle to escape further attack by Mr. McGinnis. She showed officers

injuries to her knee, arm, and an abrasion on the right side of her face. Injuries to

the left side of her face were the direct result of Mr. McGinnis’ attack; whereas, the

other injuries were the result of her jumping from the vehicle to escape Mr.

McGinnis.

After the November 2017 incident, Ms. Mitchell explained that she forgave

Mr. McGinnis. Although she forgave him, Mr. McGinnis strangled her a month

later that resulted in her presenting to the emergency room to receive treatment for

her injuries.

In December 2017, Ms. Mitchell was asleep when, around 7:00 a.m., Mr.

McGinnis kicked their bedroom door in and ordered her to take off her clothes.

According to Ms. Mitchell, Mr. McGinnis then started hitting her and tossing her

3 around the room, threatening to kill her if she tried to leave the room. At one

point, Mr. McGinnis grabbed her and “began to choke [her] from behind,” cutting

off her ability to breathe. Mr. McGinnis eventually carried her to a mirror so he

could show her, as she explained at trial, “how I look and what I make him look

like to people and how I make us look.”

After choking Ms. Mitchell, Mr. McGinnis proceeded to question Ms.

Mitchell about text messages on her phone. She stated that when she provided an

answer that Mr. McGinnis did not like he would hit her again. At approximately

5:30 p.m., when her face was extremely swollen, Ms. Mitchell asked if she could

go downstairs to get some ice. Once downstairs, Ms. Mitchell was able to escape

and call her mother for assistance, who brought her to New Orleans East Hospital

to receive treatment for her injuries.

Geraldine Mitchell, the victim’s mother, testified that, in December 2017,

she received a call from her daughter at approximately 6:30 p.m. Her daughter

asked her to come get her because Mr. McGinnis had beaten her. At trial, the

victim’s mother was asked to describe how her daughter looked when she picked

her up. Geraldine Mitchell stated, “her face was all swollen. She had a hickey on

her head. Her eyes [were] red and black underneath.” After picking her daughter

up, she testified that Mr. McGinnis called Ms. Mitchell to apologize for beating

her, indicating that he did not mean to do it.

The victim’s friend Ms. Hutson also testified with respect to the December

2017 incident. She stated that she first saw Ms. Mitchell at her mother’s house and

4 travelled with Ms. Mitchell to the hospital. She described the victim’s face as

“really, really bruised up,” and both her eyes and lips were swollen. Ms. Hutson

testified that Ms. Mitchell explained to her that Mr. McGinnis had beaten her. At

trial, she identified photographs taken of Ms. Mitchell and her injuries a few days

after the December 2017 incident. On cross-examination, Ms. Hutson admitted

that she never saw Mr. McGinnis hit the victim. Additionally, she stated that the

victim told her that the injuries she sustained in the November 2017 incident were

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State of Louisiana v. Dolan McGinnis, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-louisiana-v-dolan-mcginnis-lactapp-2020.