State of Louisiana v. Dontrelon Thomas

CourtLouisiana Court of Appeal
DecidedNovember 4, 2015
DocketKA-0015-0409
StatusUnknown

This text of State of Louisiana v. Dontrelon Thomas (State of Louisiana v. Dontrelon Thomas) 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. Dontrelon Thomas, (La. Ct. App. 2015).

Opinion

NOT DESIGNATED FOR PUBLICATION

STATE OF LOUISIANA COURT OF APPEAL, THIRD CIRCUIT

15-409

STATE OF LOUISIANA

VERSUS

DONTRELON THOMAS

**********

APPEAL FROM THE FIFTEENTH JUDICIAL DISTRICT COURT PARISH OF LAFAYETTE, NO. 144,240 HONORABLE EDWARD D. RUBIN, DISTRICT JUDGE

PHYLLIS M. KEATY JUDGE

Court composed of James T. Genovese, Shannon J. Gremillion, and Phyllis M. Keaty, Judges.

CONVICTION AND SENTENCE VACATED. REMANDED. Keith A. Stutes District Attorney Cynthia Simon Assistant District Attorney Fifteenth Judicial District Post Office Box 3306 Lafayette, Louisiana 70502-3306 (337) 232-5170 Counsel for Appellee: State of Louisiana

Chad M. Ikerd Public Defender’s Office 600 Jeffereson Street, Suite 902 Lafayette, Louisiana 70502 (337) 232-9345 Counsel for Defendant/Appellant: Dontrelon Thomas KEATY, Judge.

After a jury trial, Defendant, Dontrelon Thomas, was found guilty as

charged of armed robbery with a firearm and was later sentenced to ten years at

hard labor with credit for time served. He now appeals, alleging that the trial court

committed reversible error by replaying part of the audio of the victim’s testimony

to the jury after the jury retired to deliberate. For the following reasons, we vacate

Defendant’s conviction and sentence and remand this matter to the trial court for a

new trial.

DISCUSSION

Procedural History

Defendant was arrested October 22, 2013, and subsequently charged by bill

of indictment with one count of armed robbery with a firearm, in violation of

La.R.S. 14:64 and 14:64.3. Although Defendant was only fifteen years old at the

time of the crime, he was charged as an adult. On July 14, 2014, the trial court

heard arguments regarding a defense motion in limine and, against defense

counsel’s objections, agreed to allow the State to introduce evidence that

Defendant was wearing an ankle bracelet monitor to prove his location at the time

of the crime.1 Trial began on July 15, 2014, and concluded with the jury finding

Defendant guilty as charged.2 Thereafter, Defendant filed a motion for mistrial,

which the trial court denied. On September 22, 2014, the trial court sentenced

Defendant to ten years at hard labor with credit for time served.

1 We note that, based upon the time of the 911 call, the victim’s testimony that the police were called roughly eight-to-ten minutes after the incident, and the time stamps on the data recovered from the ankle bracelet, the testimony did nothing more than prove that Defendant was in the area roughly thirty minutes after the incident. 2 It took the jury multiple attempts to deliver a proper jury verdict form. Facts

The victim, M.V., 3 testified that he was walking down the street when he

saw a group of kids, hid his phone, and tried to walk faster. He further testified

that one of the members of the group, whom he identified as Defendant, asked him

how long he had lived in the area, then pushed him to the ground and hit him

repeatedly with a small handgun, demanding that M.V. “give it up.” M.V. further

stated that, after his phone was taken, he got up and ran home to tell his mother, at

which time the police were notified. On cross-examination, M.V. testified that the

group he saw included thirteen kids, but that he only recognized two of them: the

individual who attacked him and another teen who looked like a kid who rode his

school bus. He described his assailant as wearing a multi-colored rainbow shirt

and having “big eyes and a short Afro.”

During its closing argument, the State placed heavy emphasis on the fact that

when Defendant was arrested, he was the only person in the area who matched

M.V.’s description and was wearing a rainbow-colored shirt. After the jury retired

to deliberate, they requested M.V.’s statement, which the trial court informed them

they were not allowed to have. However, over strenuous objection by defense

counsel, the trial court played back to the jury the audio of M.V.’s testimony

regarding his assailant’s clothing. This audio playback is the basis of Defendant’s

appeal.

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 review, we note several

3 The juvenile victim in this case is identified by his initials pursuant to La.R.S. 46:1844(W).

2 errors patent. However, because of our decision to vacate Defendant’s conviction

and sentence and remand for a new trial, those errors are rendered moot.

Assignment of Error

Defendant raises a single assignment of error on appeal, namely that the trial

court committed reversible error by replaying part of the audio of the victim’s

testimony to the jury after the jury retired to deliberate, in violation of La.Code

Crim.P. art. 793. The State has failed to provide any contradictory argument.

Louisiana Code of Criminal Procedure Article 793 (emphasis added) states

the following:

A. Except as provided in Paragraph B of this Article, a juror must rely upon his memory in reaching a verdict. He shall not be permitted to refer to notes or to have access to any written evidence. Testimony shall not be repeated to the jury. Upon the request of a juror and in the discretion of the court, the jury may take with it or have sent to it any object or document received in evidence when a physical examination thereof is required to enable the jury to arrive at a verdict.

B. A juror shall be permitted to take notes when agreement to granting such permission has been made between the defendant and the state in open court but not within the presence of the jury. The court shall provide the needed writing implements. Jurors may, but need not, take notes and such notes may be used during the jury’s deliberations but shall not be preserved for review on appeal. The trial judge shall ensure the confidentiality of the notes during the course of trial and the jury’s deliberation and shall cause the notes to be destroyed immediately upon return of the verdict.

C. The lack of consent by either the defendant or the state to allow a juror to take notes during a trial shall not be communicated to the jury.

The trial court undoubtedly violated La.Code Crim.P. art. 793 when it

played an audio recording of the victim’s testimony to the jury after the jury had

begun its deliberations. The question this court must decide is whether or not that

violation represents reversible error.

3 Defendant correctly cites multiple supreme court cases which have held that

a violation of La.Code Crim.P. art. 793 is reversible error, without even a hint of

harmless error analysis. See, e.g., State v. Adams, 550 So.2d 595 (La.1989); State

v. McCully, 310 So.2d 833 (La.1975). Indeed, in McCully, the supreme court

noted that a violation of La.Code Crim.P. art. 793 was a substantial violation of a

statutory right, which “cannot under Article 921 of the Code of Criminal Procedure

be regarded as harmless[,]” and that “[t]o characterize as harmless this express and

prejudicial violation of a statutory right is to ignore the legislative mandate and, in

effect, to repeal the legislative prohibition.” McCully, 310 So.2d at 835.

Additionally, this court has previously recognized the policy basis of

La.Code Crim.P. art. 793, as follows: “Our Louisiana Supreme Court has made it

abundantly clear that allowing a jury to review evidence or testimony such as

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

Related

State v. Savoy
916 So. 2d 339 (Louisiana Court of Appeal, 2005)
State v. McCully
310 So. 2d 833 (Supreme Court of Louisiana, 1975)
State v. Johnson
726 So. 2d 1126 (Louisiana Court of Appeal, 1999)
State v. Adams
550 So. 2d 595 (Supreme Court of Louisiana, 1989)
State v. Broussard
598 So. 2d 1302 (Louisiana Court of Appeal, 1992)
State v. Baham
151 So. 3d 698 (Louisiana Court of Appeal, 2014)
State v. R.W.W.
999 So. 2d 33 (Louisiana Court of Appeal, 2008)

Cite This Page — Counsel Stack

Bluebook (online)
State of Louisiana v. Dontrelon Thomas, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-louisiana-v-dontrelon-thomas-lactapp-2015.