State of Louisiana v. Eddie Hilliard, Jr.

CourtLouisiana Court of Appeal
DecidedAugust 14, 2019
Docket52,652-KA
StatusPublished

This text of State of Louisiana v. Eddie Hilliard, Jr. (State of Louisiana v. Eddie Hilliard, Jr.) 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. Eddie Hilliard, Jr., (La. Ct. App. 2019).

Opinion

Judgment rendered August 14, 2019. Application for rehearing may be filed within the delay allowed by Art. 992, La. C. Cr. P.

No. 52,652-KA

COURT OF APPEAL SECOND CIRCUIT STATE OF LOUISIANA

*****

STATE OF LOUISIANA Appellee

versus

EDDIE HILLIARD, JR. Appellant

Appealed from the Fourth Judicial District Court for the Parish of Morehouse, Louisiana Trial Court No. 2016-50F

Honorable C. Wendell Manning, Judge

LOUISIANA APPELLATE PROJECT Counsel for Appellant By: Meghan Harwell Bitoun

EDDIE HILLIARD, JR. Pro Se

ROBERT S. TEW Counsel for Appellee District Attorney

JOHN G. SPIRES STEPHEN T. SYLVESTER Assistant District Attorneys

Before PITMAN, GARRETT, and THOMPSON, JJ. GARRETT, J.

Following a jury trial, the defendant, Eddie Hilliard, Jr., was

convicted as charged of second degree rape and attempted second degree

rape. He was sentenced, respectively, to 40 years at hard labor without

benefit of parole, probation, or suspension of sentence, and 20 years at hard

labor without benefit of parole, probation, or suspension of sentence. The

trial court imposed the sentences concurrently. A timely motion to

reconsider sentence was denied. The defendant appeals. We affirm the

defendant’s convictions and sentences.

FACTS

On the night of Saturday, October 10, 2015, the 14-year-old victim

spent the night at the apartment of her aunt, along with her sister and several

young cousins. The defendant, who was the aunt’s boyfriend and resided at

the apartment, was present that night. The next afternoon, the aunt took the

victim and her sister back to their own home. The victim’s mother noticed

that the victim was unusually reticent, teary-eyed, and refused to eat. On

Monday, October 12, 2015, the victim went to school where she

immediately sought out a paraprofessional with whom she was well

acquainted, Carla Floyd.1 Ms. Floyd said she could tell something was

wrong with the girl and took her to an office where they could talk privately.

The victim broke down and tearfully confided that she had been raped

Saturday night by the defendant. She gave Ms. Floyd some details of what

1 This witness’ maiden name is Massey and her subsequent married name is Floyd. Consequently, she is referred to in the record alternatively as “Ms. Massey,” “Ms. Floyd,” and “Ms. Massey-Floyd.” We elect to call her “Ms. Floyd” in the opinion. had happened and said that there had been two incidents that night. Ms.

Floyd alerted the principal, who called the victim’s parents and the police.

The victim was taken to a hospital where she was interviewed and

examined by Teresa Daniel, a sexual assault nurse examiner (“SANE”).

After getting a medical history and interviewing the victim about the details

of the assault, Ms. Daniel conducted a physical examination of the victim

and collected evidence, which was submitted to law enforcement as part of

the physical evidence recovery kit (“PERK”). This included oral, perineal,

anal, and external genitalia swabs.

On October 19, 2015, the victim was interviewed at the Children’s

Advocacy Center of Northeast Louisiana (“CAC”). The interview, which

was recorded, was conducted by Tiffany O’Neal, a forensic interviewer, and

monitored from another room by the center’s director, Jennifer Graves, and

Captain Anthony Evans of the Bastrop Police Department. During the

interview, the victim stated that the defendant raped her anally and

vaginally. He also tried to put his penis in her mouth.

The victim provided the clothing she was wearing at the time of the

offense to the police. The undergarments, along with the PERK kit, were

submitted to the crime lab for testing. After the police received the test

results from the crime lab, an arrest warrant was obtained, and the defendant

was arrested on January 25, 2016. By bill of information filed February 2,

2016, he was charged with one count of second degree rape and one count of

attempted second degree rape.

The defendant’s trial began on November 6, 2017. At various points

during jury selection, the trial court conducted evidentiary hearings. On

November 7, 2017, the trial court held a hearing on the state’s motion of 2 intent to use at trial the recorded testimony of a protected person, i.e., the

CAC video recording of the victim’s testimony. After hearing the testimony

of Ms. O’Neal, the CAC interviewer, and reviewing the recording in

camera, the trial court held that the state proved the videotaped interview

met the statutory requirements of competency set forth in La. R.S. 15:440.4

and the statutory requirements for admissibility established in La. R.S.

15:440.5.2 On November 8, 2017, the trial court held a competency hearing

on the victim, who was then 16 years old. The trial court found that she was

competent to testify, specifically concluding that she had a great

understanding of the gravity of the situation and the difference between truth

and falsehood. This was followed by a hearing on the admissibility of Ms.

Floyd’s testimony under La. C.E. art. 801(D)(1)(d) as the first person to

whom the rape was reported; the trial court ruled that it was admissible as

nonhearsay under that provision.

At trial, the state presented the testimony of the victim; Ms. Floyd, the

first person to whom the victim reported the rape; the victim’s mother;

Captain Evans (now the assistant police chief of the Bastrop Police

Department); Ms. Daniel, the SANE nurse; Ms. O’Neal, the CAC

interviewer; and Michelle Vrana, the DNA section supervisor and a forensic

DNA analyst at the North Louisiana Criminalistics Laboratory.3 The video

of the victim’s CAC interview was played for the jury during Ms. O’Neal’s

testimony. Ms. Vrana testified that the Y STR haplotype profile obtained

from the victim’s perineal swab and the partial Y STR haplotype profile

2 The trial court signed a written ruling to this effect on November 14, 2017. 3 Because neither the analyst who conducted the original analysis of the evidence nor the analyst who technically reviewed her analysis worked at the crime lab at the time of trial, Ms. Vrana testified as to the lab’s findings. 3 obtained from the victim’s anal swab were consistent with the Y STR

haplotype obtained from the defendant’s reference sample. Consequently,

the defendant and all males in his paternal lineage could not be excluded as a

donor. By her mathematical calculations, approximately 22,500 African-

American males in the United States could meet that criteria. While the

defendant chose not to testify, he presented the testimony of the victim’s

aunt, who was his girlfriend at the time of the offenses. The jury

unanimously convicted the defendant as charged on both counts.

The defendant filed a motion for post-verdict judgment of acquittal,

which was primarily based upon inconsistencies in the victim’s testimony; it

was denied. He also filed a motion for new trial on the same grounds.

However, he later supplemented his motion for new trial to allege that the

victim had admitted to his daughter that she lied about him raping her. At a

hearing, the defendant’s daughter testified on direct examination that the

conversation occurred a few days after the trial. On cross-examination, she

said it happened before the trial and that she told her parents about it. On

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