State of Louisiana v. Gabriel O. Hunter

CourtLouisiana Court of Appeal
DecidedFebruary 10, 2026
Docket2025-KA-0244
StatusPublished
AuthorJudge Rachael D. Johnson

This text of State of Louisiana v. Gabriel O. Hunter (State of Louisiana v. Gabriel O. Hunter) 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. Gabriel O. Hunter, (La. Ct. App. 2026).

Opinion

STATE OF LOUISIANA * NO. 2025-KA-0244

VERSUS * COURT OF APPEAL

GABRIEL O. HUNTER * FOURTH CIRCUIT

* STATE OF LOUISIANA

*******

APPEAL FROM CRIMINAL DISTRICT COURT ORLEANS PARISH NO. 536-435, SECTION “H” Honorable Camille Buras, Judge ****** Judge Rachael D. Johnson ****** (Court composed of Judge Joy Cossich Lobrano, Judge Rachael D. Johnson, Judge Karen K. Herman)

Jason Rogers DISTRICT ATTORNEY Brad Scott CHIEF OF APPEALS Zachary Phillips ASSISTANT DISTRICT ATTORNEY ORLEANS PARISH DISTRICT ATTORNEY 619 SOUTH WHITE STREET NEW ORLEANS, LA 70119

COUNSEL FOR STATE/APPELLEE

Summer Vicknair LOUISIANA APPELLATE PROJECT P. O. Box 1509 Ponchatoula, LA 70454

COUNSEL FOR DEFENDANT/APPELLANT

AFFIRMED

FEBRUARY 10, 2026 RDJ JCL KKH Appellant, defendant Gabriel O. Hunter, seeks review of his conviction for

molestation of a juvenile when the victim is under the age of thirteen and his sentence

of 50 years at hard labor, concurrent with all other counts and cases, with the first

25 years to be served without probation, parole or suspension of sentence. Finding

no error, Defendant’s conviction and sentence are affirmed.

Procedural History

On August 11, 2017, the State filed an indictment charging Defendant with

one count of aggravated rape of a juvenile under thirteen years of age, a violation of

La. Rev. Stat. 14:42(A)(4) (2013). He entered a plea of not guilty at his arraignment.

A trial (“First Trial”) was held in 2018, and by a vote of ten-to-two, the jury returned

a verdict of guilty of the lesser included offense of molestation of a juvenile under

the age of thirteen, a violation of La. Rev. Stat. 14:81.2(D)(1) (2013). Defendant was

sentenced to 50 years imprisonment at hard labor, with 25 years of which to be

served without the benefits of parole, probation, or suspension of sentence.

Defendant appealed his conviction and sentence. On appeal, this Court

vacated his non-unanimous jury verdict as unconstitutional pursuant to Ramos v.

Louisiana, 590 U.S. 83, 140 S.Ct. 1390, 206 L.Ed.2d 583 (2020). State v. Hunter,

1 19-0901 (La. App. 4 Cir. 5/27/20), 364 So.3d 249.1 The State re-instituted

prosecution on the charge of molestation of a juvenile under the age of thirteen.

In 2024, Defendant filed a motion to quash, arguing that he was subjected to

double jeopardy as he was acquitted of the element of the victim being under the age

of thirteen. The district court denied his motion. Defendant sought review of that

ruling; however, both this Court and the Louisiana Supreme Court denied writs.

State v. Hunter, 24-0145 (La. App. 4 Cir. 3/13/24), writ denied, 24-00370 (La.

4/10/24), 383 So.3d 157.

Defendant’s second trial, at issue here, commenced on August 5, 2024, and

the jury returned a unanimous verdict of guilty as charged, aggravated rape of a

juvenile under thirteen years of age, which is defined by La. Rev. Stat. 14:42(A)(4)

(2013) as the commission of anal, oral, or vaginal sexual intercourse with a person

under the age of thirteen, where the victim is deemed incapable of lawful consent as

a matter of law. The district court imposed the same sentence as Defendant’s initial

sentence, over his objection: 50 years imprisonment at hard labor, 25 years of which

must be served without the benefits of parole, probation, or suspension of sentence.

This timely appeal followed.

1 Defendant filed several pro se motions following the reversal of his conviction and sentence

seeking writs of mandamus; review of his (incorrectly styled) motion to quash; the court’s failure to recuse itself; and the court’s failure to appoint conflict-free counsel. Nevertheless, because many of his complaints primarily addressed his first conviction, which was ultimately reversed, the issues raised were mostly moot. See State v. Hunter, 20-0270 (La. App. 4 Cir. 7/1/20); State v. Hunter, 20-0637 (La. App. 4 Cir. 12/15/20), writ denied, 21-056 (La. 2/17/21), 310 So.3d 1151; State v. Hunter, 21-0257 (La. App. 4 Cir. 5/13/21); State v. Hunter, 21-0321 (La. App. 4 Cir. 6/2/21); State v. Hunter, 21-0362 (La. App. 4 Cir. 6/22/21); State v. Hunter, 21-0424 (La. App. 4 Cir. 7/16/21), writ denied, 21-01247 (La. 12/21/21), 329 So.3d 826.

2 Facts

At trial, the State presented testimony from six witnesses: two medical

professionals, the victim’s mother, a law enforcement officer, a forensic interviewer,

and the victim. The defense presented no witnesses.

Initial Disclosure and 2015 Medical Evaluation

In 2015, when the victim was eleven years old, she disclosed allegations of

sexual abuse through a handwritten note given to her mother. The note described

abuse and expressed fear of disclosing the allegations earlier, including concern

about the consequences for others and fear of getting into trouble. Upon receiving

the note, the victim’s mother sought immediate medical care and reported the

allegations.

The victim was first evaluated in the emergency department at Children’s

Hospital in New Orleans and was then referred for a forensic interview and medical

examination conducted by Dr. Anne Troy, a pediatric forensic nurse practitioner.

The forensic interview was audio and video recorded pursuant to hospital protocol.

The recording was admitted into evidence and played for the jury.

Dr. Troy testified that during the interview, the victim provided a narrative

describing repeated incidents of sexual contact with Defendant occurring over a

period of time and in more than one location. Dr. Troy testified that the victim

described the circumstances under which the incidents occurred, including that the

alleged abuse took place during periods when the victim was living in a household

where Defendant resided, and explained her emotional responses, including fear and

confusion. Dr. Troy documented the victim’s account contemporaneously in her

written report.

3 Dr. Troy further testified that the victim’s mother reported that, prior to the

disclosure, the victim had been experiencing behavioral and disciplinary issues at

school, including fighting and defiance. Dr. Troy explained that such behavioral

changes may be associated with trauma or abuse, particularly in children who have

not yet disclosed.

Dr. Troy testified that the physical examination revealed no observable signs

of sexual trauma and that an earlier emergency department examination also yielded

normal findings. She explained that the absence of physical findings was not

unexpected given the delayed nature of the disclosure and the tendency for genital

injuries to heal quickly. Based on the victim’s statements, Dr. Troy characterized the

history as consistent with repeated or chronic sexual abuse.

Dr. Troy forwarded her report, including the recorded interview, to the New

Orleans Police Department as part of the hospital’s standard reporting process. She

testified that she was not contacted for follow-up and was unaware of any immediate

investigative action related to the 2015 disclosure.

Subsequent Behavioral Changes and Second Disclosure

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Related

State v. Fuller
454 So. 2d 119 (Supreme Court of Louisiana, 1984)
State v. Brauner
782 So. 2d 52 (Louisiana Court of Appeal, 2001)
State v. Every
35 So. 3d 410 (Louisiana Court of Appeal, 2010)
State v. Cook
674 So. 2d 957 (Supreme Court of Louisiana, 1996)
State v. Porter
639 So. 2d 1137 (Supreme Court of Louisiana, 1994)
State v. Mims
619 So. 2d 1059 (Supreme Court of Louisiana, 1993)
State v. Jenkins
750 So. 2d 366 (Louisiana Court of Appeal, 1999)
State v. Parker
76 So. 3d 55 (Louisiana Court of Appeal, 2011)
Ramos v. Louisiana
590 U.S. 83 (Supreme Court, 2020)
State v. Wilson
138 So. 3d 661 (Louisiana Court of Appeal, 2014)
State v. Ambeau
6 So. 3d 215 (Louisiana Court of Appeal, 2009)
Ramos v. Louisiana
140 S. Ct. 1390 (Supreme Court, 2020)

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State of Louisiana v. Gabriel O. Hunter, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-louisiana-v-gabriel-o-hunter-lactapp-2026.