State of Louisiana v. Edward R. Budd

CourtLouisiana Court of Appeal
DecidedJuly 26, 2024
Docket2023-KA-0594
StatusPublished

This text of State of Louisiana v. Edward R. Budd (State of Louisiana v. Edward R. Budd) 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. Edward R. Budd, (La. Ct. App. 2024).

Opinion

STATE OF LOUISIANA * NO. 2023-KA-0594

VERSUS * COURT OF APPEAL EDWARD R. BUDD * FOURTH CIRCUIT * STATE OF LOUISIANA *******

APPEAL FROM CRIMINAL DISTRICT COURT ORLEANS PARISH NO. 553-085, SECTION “A” Honorable Simone A. Levine1 ****** Judge Dale N. Atkins ****** (Court composed of Chief Judge Terri F. Love, Judge Roland L. Belsome, Judge Dale N. Atkins)

Edward R. Budd #776604 Dixon Correctional Center P. O. Box 788 Jackson, LA 70748

APPELLANT

Mary Constance Hanes LOUISIANA APPELLATE PROJECT 1538 Short Street New Orleans, LA 70118

COUNSEL FOR APPELLANT, Edward R. Budd

Jason R. Williams, District Attorney Brad Scott, Chief of Appeals Zachary M. Phillips, Assistant District Attorney ORLEANS PARISH DISTRICT ATTORNEY’S OFFICE 619 S. White Street New Orleans, LA 70119

COUNSEL FOR APPELLEE, State of Louisiana

1 We note that the presiding and sentencing judge was the Honorable Laurie

A. White. SENTENCE VACATED; REMANDED FOR RESENTENCING JULY 26, 2024 DNA

TFL

RLB

This is a criminal matter. Appellant, Edward R. Budd (“Mr. Budd”), appeals

the sentence he received for his conviction of sexual battery, a violation of La R.S.

14:43.1(A)(1). On appeal, Mr. Budd argues that his sentence is unconstitutionally

excessive. Mr. Budd’s appeal also asks this court to resolve the discrepancy

between the trial transcript, in which the district court judge announced the verdict

as guilty of sexual battery, and the minute entry, which reflects that he was

convicted of third-degree rape. For the reasons that follow, we vacate Mr. Budd’s

sentence, and we remand for resentencing in accordance with La. R.S.

14:43.1(C)(1). We further remand for the purpose of correcting the minute and

docket master entries, as well as the sentencing commitment order, to reflect that

Mr. Budd was convicted of sexual battery, a violation of La. R.S. 14:43.1(A)(1).

In all other respects, Mr. Budd’s conviction is affirmed.

STATEMENT OF THE CASE

On January 10, 2022, the State of Louisiana (“State”) charged Mr. Budd, by

bill of information in Case Number 553-085 with the May 14, 2021 third-degree

rape of C.K.,2 a felony in violation of La. R.S. 14:43 (“C.K. Case”). At that time, a

2 Because of the nature of the crimes alleged herein, this Opinion will refer

to all of the alleged sex offense victims by their initials to protect their identities. 1 charge of first-degree rape of a different victim, H.W., a violation of La. R.S. 1442,

was pending against Mr. Budd and his co-defendant Echo Hurlburt (“Mr.

Hurlburt”) in a different case, Case Number 547-278, in section “A” of Orleans

Parish Criminal District Court (“H.W. Case”). Because of the pending H.W. Case,

the district court transferred the C.K. Case to Section “A.” On March 7, 2022, Mr.

Budd entered a plea of not guilty in the C.K. Case.

On April 1, 2022, in the C.K. Case, the State filed a “Notice to Introduce

Evidence of . . . Sexually Assaultive Behavior Pursuant to La. C.E. art. 412.2”

(“First Notice”).3 In this First Notice, the State sought to introduce evidence of Mr.

Budd’s alleged aggravated rape of H.W. in 2019. The district court “granted” the

State’s First Notice and announced that the C.K. Case and the H.W. Case would be

tried together.

On May 16, 2022, defense counsel filed a waiver of the constitutional right

to a jury trial. The State filed an opposition arguing that the waiver was untimely;

but the State subsequently withdrew its opposition on May 26, 2022. Then, on May

28, 2022, Mr. Budd waived his right to a trial by jury and signed a written waiver

of rights, after which the district court granted a judge trial.

See La. R.S. 46:1844(W)(1)(a) (providing that “[i]n order to protect the identity and provide for the safety and welfare of . . . victims of sex offenses . . . all public officials and officers and public agencies, including but not limited to . . . judicial officers, . . . shall not publicly disclose the name, address, contact information, or identity of . . . victims of sex offenses . . . .”). See also State v. McDonough, 2022- 0628, p. 1 (La. App. 4 Cir. 10/27/23), 376 So.3d 1003, 1009 n.1 (quoting La. R.S. 46:1844(W)(1)(a)). 3 Louisiana Code of Evidence Article 412.2 is titled “Evidence of similar

crimes, wrongs, or acts in sex offense cases.” It states that “[w]hen an accused is charged with a crime involving sexually assaultive behavior,” then “evidence of the accused’s commission of another crime, wrong, or act involving sexually assaultive behavior . . . may be admissible and may be considered for its bearing on any matter to which it is relevant subject to” a balancing test provided in La. C.E. art. 403. 2 Thereafter, on September 29, 2022, the State filed another “Notice of Intent

to Introduce Evidence of Sexually Assaultive Behavior Pursuant to La. C.E. art.

412.2” (“Second Notice”). Therein, the State sought to introduce evidence of three

prior sexual offenses allegedly committed by Mr. Budd against L.W., A.M., and a

fellow student when he was in high school. The district court held a hearing on the

State’s Second Notice on October 5, 2022, and denied the State’s Second Notice.

The State filed a writ application with this Court concerning the district court’s

denial of its Second Notice, but this Court denied the State’s writ application.4 The

State did not seek review with the Louisiana Supreme Court.

On October 11, 2022, the State amended its Second Notice so that it

contained only the alleged prior sexual offense committed by Mr. Budd against

L.W. (“Amended Second Notice”).5 In response, Mr. Budd’s defense counsel

informed the district court that the State showed him the Amended Second Notice,

which had more specific details thereby enabling the defense to investigate for trial

preparation. Further, defense counsel stated that the Amended Second Notice

complied with the requirements of La. C.E. art. 412.2. Without any objection from

defense counsel, the district court “granted” the State’s Amended Second Notice.

On November 2, 2022, the case proceeded to a bench trial. The district court

found Mr. Budd not guilty of the first-degree rape of H.W. As to C.K., the district

court found Mr. Budd guilty of a lesser charge, sexual battery. However, the

4 State of Louisiana v. Edward Budd, 2022-K-0661 (La. App. 4 Cir. 10/7/22). 5 That is, the State no longer sought to introduce evidence of the prior sexual

offenses allegedly committed by Mr. Budd against A.M. and a fellow student when he was in high school. 3 docket master and minute entry indicate the district court found Mr. Budd guilty of

third-degree rape of C.K.

Mr. Budd appeared for sentencing on December 1, 2022, and on the same

day filed a motion for new trial, which the district court denied. Mr. Budd waived

all delays, and the district court sentenced him to ten years’ imprisonment at hard

labor with two years suspended and to be served concurrently with any other

sentences. The district court also sentenced Mr. Budd to five years of active

probation following his release and ordered that he participate in psychiatric

counseling. Finally, the district court ordered Mr. Budd to register as a sex

offender for fifteen years.

On December 7, 2022, Mr. Budd filed a motion to reconsider sentence,

which the district court denied. Mr. Budd filed a motion for appeal on January 21,

2023, which the district court granted on the same day. His timely appeal to this

Court followed.

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State of Louisiana v. Edward R. Budd, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-louisiana-v-edward-r-budd-lactapp-2024.