State of Louisiana v. Emeterio L. Rivera

CourtLouisiana Court of Appeal
DecidedNovember 9, 2022
DocketKA-0022-0365
StatusUnknown

This text of State of Louisiana v. Emeterio L. Rivera (State of Louisiana v. Emeterio L. Rivera) 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. Emeterio L. Rivera, (La. Ct. App. 2022).

Opinion

NOT DESIGNATED FOR PUBLICATION

STATE OF LOUISIANA COURT OF APPEAL, THIRD CIRCUIT

22-365

STATE OF LOUISIANA

VERSUS

EMETERIO RIVERA

*********

APPEAL FROM THE SIXTEENTH JUDICIAL DISTRICT COURT PARISH OF IBERIA, NO. 18-1485 HONORABLE KEITH R.J. COMEAUX, DISTRICT JUDGE

**********

CHARLES G. FITZGERALD JUDGE

Court composed of Sylvia R. Cooks, Chief Judge, and Charles G. Fitzgerald and Gary J. Ortego, Judges

CONVICTION AFFIRMED; SENTENCE VACATED AND REMANDED. Chad M. Ikerd Louisiana Appellate Project Post Office Box 2125 Lafayette, Louisiana 70502 (337) 366-8994 Counsel for Defendant/Appellant: Emeterio Rivera

Bofill Duhé District Attorney Alister Charrier W. Claire Howington Assistant District Attorneys 300 Iberia Street, Suite 200 New Iberia, Louisiana 70560 (337) 369-4420 Counsel for Appellee: State of Louisiana FITZGERALD, Judge. Defendant, Emerterio Rivera, appeals his convictions of first degree rape and

sexual battery.

PROCEDURAL HISTORY

In December 2018, Defendant was charged by grand jury indictment with two

counts of first degree rape of a juvenile under the age of 13, in violation of La R.S.

14:42, and one count of sexual battery of a juvenile under the age of 13, in violation

of La R.S. 14:43.1. As alleged in the indictment, the criminal conduct took place in

Iberia Parish in June 2017 when A.H., the minor child, was 12 years old.

A four-day jury trial commenced in April 2021. At the close of evidence, the

jury unanimously found Defendant guilty on all counts. Two months later,

Defendant filed a motion for new trial based on a juror’s affidavit. The trial court

ultimately excluded the affidavit and denied Defendant’s motion.

On December 15, 2021, the trial court imposed a life sentence for first degree

rape and thirty years for sexual battery. The court ordered the sentences to run

concurrently. Defendant appealed.

LAW AND ANALYSIS

I. ERRORS PATENT

In accordance with La.Code Crim P. art. 920, we review all criminal appeals

for errors patent on the face of the record. Here, there are two errors patent. First,

the rape sentence is indeterminate. And second, the sentence for first degree rape

must be served at hard labor.

The sentence imposed for the two counts of first degree rape is indeterminate

because the trial court imposed a single life sentence for both counts. Specifically,

at the sentencing hearing, the trial court stated: Therefore, under the provisions of Title 14, Section 43.1, on the sexual battery, I sentence him to a term of imprisonment of thirty years at hard labor. Twenty-five of those years will be served without the benefit of probation, parole, or suspension of sentence as provided by statute.

Additionally, on the two counts of first degree rape, the Court will sentence the defendant to life imprisonment without benefit of probation, parole, or suspension of sentence. For the purposes of execution of those sentences, the sentences shall run concurrently with each other.

“Where the trial court has imposed one sentence for multiple counts, this court

has previously set aside the defendant’s sentence on those counts as indeterminate

and remanded the case to the trial court for resentencing on each count.” State v.

Grace, 10-1222, p. 19 (La.App. 3 Cir. 4/6/11), 61 So.3d. 812, 825-26, writ denied,

11-961 (La. 10/21/11), 73 So.3d. 382. See also La.Code Crim.P. art 879 (If “a

defendant who has been convicted of an offense is sentenced to imprisonment, the

court shall impose a determinate sentence.”).

Thus, the single sentence imposed for the two counts of first degree rape is

vacated and the case is remanded to the trial court for resentencing on each of the

first degree rape counts separately.

The trial court also failed to specify that the sentence imposed for first degree

rape must be served at hard labor. Louisiana Revised Statutes 14:42(D)(2), as

applicable to this case, provides a mandatory sentence of life imprisonment at hard

labor without the benefit of parole, probation, or suspension of sentence in cases

involving victims under the age of thirteen.

On remand, the trial court is instructed to resentence Defendant at hard labor.

2 II. ASSIGNMENT OF ERROR NUMBER 1

In his first assignment of error, Defendant asserts that the trial court erred by

refusing to answer a jury question regarding the possibility of a hung jury. The

record reflects the following exchange during jury deliberations:

THE COURT:

I’ve been presented with a question from the foreperson, I gather, Ms. Viator and we cannot agree to a unanimous decision. A juror will not even agree to lesser charges. We want to understand next steps if only one juror will never be convinced of any guilty pleas on all charges. I’m going to read to you the deliberation instructions again, the pertinent parts I think are pertinent.

First of all I don’t think y’all have bene [sic] out long enough. Okay. It is your duty to follow these instructions in reaching your verdict. As jurors, you are not to be influenced by mere sympathy, passion, prejudice or public opinion. You are expected to reach a just verdict. It is your duty to consult with one another and to deliberate with a view to reaching an agreement, if you can do so without violence to your individual judgment. You must each decide the case for yourself, but only after an impartial consideration of the evidence in the case, with your fellow jurors. In the course of your own views, or change your opinion, if convinced it is erroneous. But do not surrender your honest conviction as to the weight or effect of evidence, solely because of the opinion of your fellow jurors, or for the mere purpose of returning a verdict. Let me say that it is usually not a good idea for a juror, when first entering the jury room, to make an emphatic expression of an opinion on the case or announce a determination to stand for a certain verdict. When one does that at the outset, a sense of pride may be at issue; one may hesitate to back down from an announced position, even if shown to be wrong. Remember, you are not advocates in this matter, but rather you are judges. Your sole interest is to seek the truth from the evidence case. Your verdict must be unanimous. When all of you agree on the same verdict on each count, whatever it might be, you may render it. Okay. I got pizzas coming. They’ll be here shortly. I’d like y’all to return back to deliberate some more.

THE BAILIFF:

Please rise for the jury.

(Jury out)

3 THE COURT:

I’m going to offer this as Court Exhibit Number?

THE CLERK:

Court 8.

Okay. Any objection to the charge that I gave?

MS. CHARRIER:

No, Your Honor.

MR. SPEARS:

Court is in recess.

Louisiana Code of Criminal Procedure Article 801(C) sets forth the

contemporaneous objection requirement, stating:

C. A party may not assign as error the giving or failure to give a jury charge or any portion thereof unless an objection thereto is made before the jury retires or within such time as the court may reasonably cure the alleged error. The nature of the objection and grounds therefor shall be stated at the time of objection. The court shall give the party an opportunity to make the objection out of the presence of the jury. The record reflects that Defendant not only failed to contemporaneously

object to the trial court’s supplemental instructions to the jury, but acquiesced to the

supplemental instructions. Consequently, this issue is not preserved for appellate

review.

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State of Louisiana v. Emeterio L. Rivera, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-louisiana-v-emeterio-l-rivera-lactapp-2022.