State of Louisiana v. Frederick Lathan

CourtLouisiana Court of Appeal
DecidedJanuary 12, 2022
Docket54,181-KA
StatusPublished

This text of State of Louisiana v. Frederick Lathan (State of Louisiana v. Frederick Lathan) 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. Frederick Lathan, (La. Ct. App. 2022).

Opinion

Judgment rendered January 12, 2022. Application for rehearing may be filed within the delay allowed by Art. 922, La. C. Cr. P.

No. 54,181-KA

COURT OF APPEAL SECOND CIRCUIT STATE OF LOUISIANA

*****

STATE OF LOUISIANA Appellee

versus

FREDERICK LATHAN Appellant

Appealed from the Twenty-Sixth Judicial District Court for the Parish of Bossier, Louisiana Trial Court No. 222,280

Honorable Michael Nerren, Judge

LOUISIANA APPELLATE PROJECT Counsel for Appellant By: Chad Ikerd

J. SCHUYLER MARVIN Counsel for Appellee District Attorney

JOHN MICHAEL LAWRENCE DOUGLAS M. STINSON CHRISTOPHER WARREN Assistant District Attorneys

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

Frederick Lathan appeals his conviction by a Bossier Parish jury and

sentence to life in prison at hard labor, without the possibility of parole,

probation, or suspension of sentence for first degree rape. Lathan argues

that the State failed to sufficiently prove that he was guilty of first degree

rape because there was insufficient evidence that the child victim resisted to

the utmost, as required by the applicable statute. For the following reasons,

we affirm the defendant’s conviction and sentence.

FACTS

The victim in this matter was the 14-year-old daughter of Lathan’s

girlfriend. Lathan entered the bedroom of the victim, M.R., while she was

sleeping. M.R. testified that she was asleep in her room, lying on her

stomach and did not initially hear Lathan enter her room. M.R. testified that

Lathan moved the covers off of her and pulled her pants down her legs.

M.R. testified that “[h]e was pushing my head down and he put his private

area in mine’s (sic).” M.R. testified that she tried to get him off of her but

Lathan was still pushing her head down into her pillow. M.R. testified that

she was moving her arms and “trying to get him from behind me.” When

asked if she tried to get out of the situation – Lathan pushing her head down

into the pillow from behind her – she stated that she tried “[a]s hard as I

could.”

On cross-examination, when asked about this rape, M.R. testified that

she could not yell out for her mother due to her head being pushed down into

the pillow. M.R. testified that “she was hollering but it was muffled from

the pillows.” Following this first rape, Lathan told M.R. not to tell her

mother or anyone else. M.R. testified that she did not go to wake her mother up that night after the rape, because she felt that her mother would not

believe her. M.R. also testified that she was “so traumatized of it I just

never got up and said nothing. I just sat there and cried.”

The following morning, Lathan raped M.R. a second time. M.R.

testified that Lathan told her to come into his room. When she entered his

room, M.R. stated that “he pushed me down on the bed and pulled my pants

down again.” Lathan closed the door and had loud music playing in the

room. M.R. testified that Lathan would “flip the positions,” physically

moving her into different positions while he raped her. Lathan also made

M.R. perform oral sex on him. M.R. stated that Lathan “was grabbing on

me everywhere.” After the second rape, she tried to find her brother but did

not tell him what happened to her.

M.R. testified that Lathan raped her for a third time, that same

morning. Lathan again told M.R. to come into his room. M.R. testified that

he pushed her on the bed again, pulled down her pants, and raped her. M.R.

testified that during the two rapes that occurred in the morning, she tried to

resist Lathan by punching on his back and scratching him. M.R. testified

that Lathan was holding her down, biting her, and choking her with his

hands. When asked how hard she tried to resist Lathan, M.R. testified that

she tried “her hardest.”

After the third rape, M.R. left her house and ran to her aunt’s house

nearby and reported the rapes to her aunt and maternal grandmother. They

immediately took her to the hospital, where a Sexual Assault Nurse

Examiner (“SANE”) performed a rape kit examination. DNA swabs were

taken and tested, and Lathan’s DNA was found on the swabs from M.R.’s

external genitalia. There was prostate specific antigen (“PSA”), which is a 2 component of semen, found on the cervical swabs collected. Lathan could

not be confirmed or excluded as the source of the PSA found on M.R. The

SANE nurse did not note any physical evidence of bite marks on M.R. M.R.

gave a statement at the Gingerbread House regarding the assaults.

At trial, Lathan testified that he never had sex with M.R., and he did

not know why she would make up the allegations. M.R. admitted to lying

about her grandfather molesting her when she was forced to stay with him,

prior to this incident. M.R.’s mother, who married Lathan after the rape of

her daughter, testified that she did not believe her daughter and believed

Lathan was innocent.

The Bossier Parish jury unanimously convicted Lathan of first degree

rape. The trial court sentenced Lathan to life in prison at hard labor, without

the possibility of parole, probation or suspension. This appeal followed.

DISCUSSION

Lathan asserts only one assignment of error, focused on the extent of

resistance of his 14-year-old victim.

Assignment of Error: The State failed to sufficiently prove that Frederick Lathan was guilty of first degree rape. The evidence did not prove that M.R. resisted to her utmost, an essential element of the crime. Instead, the state only proved the lesser offense of second degree rape.

The standard of appellate review for a sufficiency of the evidence

claim is whether, after viewing the evidence in the light most favorable to

the prosecution, any rational trier of fact could have found the essential

elements of the crime beyond a reasonable doubt. Jackson v. Virginia, 443

U.S. 307, 99 S. Ct. 2781, 61 L. Ed. 2d 560 (1979); State v. Hearold, 603 So.

2d 731 (La. 1992); State v. Smith, 47,983 (La. App. 2 Cir. 5/15/13), 116 So.

3d 884. See also La. C. Cr. P. art. 821. 3 The appellate court does not assess the credibility of witnesses or

reweigh the evidence. State v. Smith, 94-3116 (La. 10/16/95), 661 So. 2d

442; State v. Dale, 50,195 (La. App. 2 Cir. 11/18/15), 180 So. 3d 528, writ

denied, 15-2291 (La. 4/4/16), 190 So. 3d 1203. A reviewing court affords

great deference to a trial court’s decision to accept or reject the testimony of

a witness in whole or in part. State v. Steines, 51,698 (La. App. 2 Cir.

11/15/17), 245 So. 3d 224, writ denied, 17-2174 (La. 10/8/18), 253 So. 3d

797. In the absence of internal contradictions or irreconcilable conflict with

physical evidence, the testimony of one witness is sufficient support for a

requisite factual conclusion if that witness is believed by the trier of fact.

State v. Jones, 31,613 (La. App. 2 Cir. 4/1/99), 733 So. 2d 127, writ denied,

99-1185 (La. 10/1/99), 748 So. 2d 434.

On June 29, 2015, the Louisiana Legislature approved 2015 La. Acts

256, which amended and reenacted the introductory paragraphs of La. R.S.

14:42 and La. R.S. 14:42.1 to rename the crimes of “aggravated rape” and

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Related

Jackson v. Virginia
443 U.S. 307 (Supreme Court, 1979)
State v. Smith
661 So. 2d 442 (Supreme Court of Louisiana, 1995)
State v. Jones
733 So. 2d 127 (Louisiana Court of Appeal, 1999)
State v. Hearold
603 So. 2d 731 (Supreme Court of Louisiana, 1992)
MATTHEW JOSEPH DETTLE v. State of Florida
226 So. 3d 285 (District Court of Appeal of Florida, 2017)
State v. Smith
116 So. 3d 884 (Louisiana Court of Appeal, 2013)
State v. Carter
160 So. 3d 647 (Louisiana Court of Appeal, 2015)
State v. Dale
180 So. 3d 528 (Louisiana Court of Appeal, 2015)
State v. Thibeaux
229 So. 3d 967 (Louisiana Court of Appeal, 2017)
State v. Steines
245 So. 3d 224 (Louisiana Court of Appeal, 2017)

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State of Louisiana v. Frederick Lathan, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-louisiana-v-frederick-lathan-lactapp-2022.