State of Louisiana v. Henrietta Williams

CourtLouisiana Court of Appeal
DecidedMarch 7, 2007
DocketKA-0006-1247
StatusUnknown

This text of State of Louisiana v. Henrietta Williams (State of Louisiana v. Henrietta Williams) 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. Henrietta Williams, (La. Ct. App. 2007).

Opinion

STATE OF LOUISIANA COURT OF APPEAL, THIRD CIRCUIT

06-1247

STATE OF LOUISIANA

VERSUS

HENRIETTA WILLIAMS

************

APPEAL FROM THE SEVENTH JUDICIAL DISTRICT COURT, PARISH OF CONCORDIA, NO. 06-021MH, HONORABLE SHARON MARCHMAN, DISTRICT JUDGE

MICHAEL G. SULLIVAN JUDGE

Court composed of Ulysses Gene Thibodeaux, Chief Judge, Oswald A. Decuir, and Michael G. Sullivan, Judges.

CONVICTION AFFIRMED; SENTENCE VACATED; AND REMANDED WITH INSTRUCTIONS.

John Frederick Johnson District Attorney 4001 Carter Street, Suite 9 Vidalia, Louisiana 71373 (318) 336-5526 Counsel for: State of Louisiana

Charles C. Foti, Jr. Attorney General Molly L. Balfour Assistant Attorney General Post Office Box 94005 Baton Rouge, Louisiana 70804 (225) 326-6200 Counsel for: State of Louisiana Raymond Lee Cannon Attorney at Law Post Office Box 1108 Tallulah, Louisiana 71282-1108 (318) 574-2500 Counsel for Defendant/Appellant: Henrietta Williams

Butch Wilson Assistant Attorney General Post Office Box 2391 Baton Rouge, Louisiana 70821 (225) 326-6000 Counsel for: State of Louisiana SULLIVAN, Judge.

On March 3, 2006, the Attorney General’s Office filed a bill of information in

Concordia Parish charging Henrietta Williams (hereinafter “Defendant”) with filing

a false public record, i.e., a false absentee ballot affidavit, in violation of La.R.S.

14:133. Following a jury trial on March 9, 2006, Defendant was found guilty as

charged.

On May 19, 2006, the trial court heard and denied Defendant’s motions for

arrest of judgment, post verdict judgment of acquittal, and new trial. Defendant then

waived sentencing delays, and the trial court sentenced her to five years at hard labor,

with all but eighteen months suspended, and five years of supervised probation.

Defendant filed a motion to reconsider the sentence, which the trial court heard and

denied on July 7, 2006.

Defendant now seeks review by this court, assigning five errors. For the

following reasons, we affirm Defendant’s conviction, but we vacate Defendant’s

sentence and remand with instructions.

Facts

On April 1, 2004, while at the home of Maud Williams (hereinafter

“Ms. Williams”) in Ferriday, Louisiana, Defendant helped Ms. Williams fill out an

absentee voting ballot. Ms. Williams’ two adult granddaughters, Renasha Reed and

Felicia Williams, were also at the residence, and Defendant asked them to sign as

witnesses to Ms. Williams’ signature on the “affidavit flap” of the mail-in ballot’s

envelope. The granddaughters refused because they had heard Defendant telling

Ms. Williams for whom to vote.

Defendant became upset and left with the ballot envelope and ballot. She then

visited the homes of Shirley Mason and Eloise Polk, asking each of them to sign as witnesses, which they did. The Registrar of Voters for Concordia Parish received the

absentee ballot in Ms. Williams’ name the next day, April 2, 2004.

Errors Patent

In accordance with La.Code Crim.P. art. 920, this court reviews all appeals for

errors patent on the face of the record. After reviewing the record, we find that the

court minutes of trial require correction.

First, the court minutes indicate that the alternate juror was excused prior to the

jury retiring for deliberation; however, the minutes then list the alternate juror’s vote

during polling. The trial transcript confirms that the alternate juror was released prior

to deliberations and was not polled with the other jurors. Second, there is a

discrepancy between the minutes and the transcript as to which trial court judge

presided over the reconsideration hearing.1 Accordingly, we will remand with

instructions that the trial court correct the court minutes to reflect that the alternate

juror was not polled and to identify which judge presided over the reconsideration

hearing.

Assignment of Error No. 2

Although Defendant’s brief combines her second assignment of error with her

fourth, we will address it separately, as it challenges the sufficiency of the evidence.

Such an argument must be addressed first on appellate review, since a holding that

the evidence was insufficient would necessitate an acquittal. State v. Hearold, 603

So.2d 731 (La.1992).

The analysis for sufficiency reviews is well-settled, as this court has explained:

1 The minutes reflect that Judge Sharon Marchman, who conducted the trial, also presided at the reconsideration hearing, whereas the transcript suggests that Judge Kathy Johnson presided over that hearing. Although the transcript normally controls in such conflicts, some of the discussion during the hearing suggests that the judge at the hearing had presided over earlier proceedings.

2 When the issue of sufficiency of evidence is raised on appeal, the critical inquiry of the reviewing court 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 proven beyond a reasonable doubt. Jackson v. Virginia, 443 U.S. 307, 99 S.Ct. 2781, 61 L.Ed.2d 560, rehearing denied, 444 U.S. 890, 100 S.Ct. 195, 62 L.Ed.2d 126 (1979); State ex rel. Graffagnino v. King, 436 So.2d 559 (La.1983); State v. Duncan, 420 So.2d 1105 (La.1982); State v. Moody, 393 So.2d 1212 (La.1981). It is the role of the fact finder to weigh the respective credibility of the witnesses, and therefore, the appellate court should not second guess the credibility determinations of the triers of fact beyond the sufficiency evaluations under the Jackson standard of review. See State ex rel. Graffagnino, 436 So.2d 559 (citing State v. Richardson, 425 So.2d 1228 (La.1983)). In order for this Court to affirm a conviction, however, the record must reflect that the state has satisfied its burden of proving the elements of the crime beyond a reasonable doubt.

State v. Kennerson, 96-1518, p. 5 (La.App. 3 Cir. 5/7/97), 695 So.2d 1367, 1371.

Defendant was convicted of filing a false public record, specifically, a false

absentee ballot affidavit. The relevant statute is La.R.S. 14:133, which states in part:

A. Filing false public records is the filing or depositing for record in any public office or with any public official, or the maintaining as required by law, regulation, or rule, with knowledge of its falsity, of any of the following:

....

(3) Any document containing a false statement or false representation of a material fact.

Defendant argues that the evidence is insufficient to support her conviction

because “[n]o signature on the ballot is forged or misrepresented” and “[t]he ballot

itself contains no clause that the witnesses to the voter’s signature on the ballot must

sign in the presence of witnesses or vice versa.” However, we note that the ballot

affidavit at issue includes a certification of truth that must be signed by the voter,

whose signature line is followed by the clause, “Sworn to and subscribed before me

on[,]” then a few lines for a notary or registrar to sign, and below those, each of the

3 two purported witnesses’ signatures appears on a line that bears the designation

“witness.” We find it clear that signing as a witness that a signed certification of truth

was sworn to and subscribed in the signer’s presence, when in fact it was not,

constitutes a false representation for purposes of the statute. By filing such a

document into the public record, Defendant violated the statute.

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Related

Jackson v. Virginia
443 U.S. 307 (Supreme Court, 1979)
Kolender v. Lawson
461 U.S. 352 (Supreme Court, 1983)
Bearden v. Georgia
461 U.S. 660 (Supreme Court, 1983)
Strickland v. Washington
466 U.S. 668 (Supreme Court, 1984)
Batson v. Kentucky
476 U.S. 79 (Supreme Court, 1986)
State v. LeCompte
406 So. 2d 1300 (Supreme Court of Louisiana, 1981)
State v. Barling
779 So. 2d 1035 (Louisiana Court of Appeal, 2001)
State v. Kennerson
695 So. 2d 1367 (Louisiana Court of Appeal, 1997)
State v. Montalban
810 So. 2d 1106 (Supreme Court of Louisiana, 2002)
State v. Richardson
425 So. 2d 1228 (Supreme Court of Louisiana, 1983)
State v. Monson
576 So. 2d 517 (Supreme Court of Louisiana, 1991)
State v. King
935 So. 2d 354 (Louisiana Court of Appeal, 2006)
State v. Broom
439 So. 2d 357 (Supreme Court of Louisiana, 1983)
State v. Collins
763 So. 2d 618 (Louisiana Court of Appeal, 1999)
State v. Muschkat
706 So. 2d 429 (Supreme Court of Louisiana, 1998)
State v. Williams
800 So. 2d 790 (Supreme Court of Louisiana, 2001)
State v. Butler
331 So. 2d 425 (Supreme Court of Louisiana, 1976)
Adkins v. Huckabay
755 So. 2d 206 (Supreme Court of Louisiana, 2000)
State Ex Rel. Graffagnino v. King
436 So. 2d 559 (Supreme Court of Louisiana, 1983)
State v. Barthelemy
545 So. 2d 531 (Supreme Court of Louisiana, 1989)

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