State of Louisiana v. Howard E. Blue

Louisiana Court of Appeal·Decided August 21, 2025·No. 2024-KA-0737·Published

Opinion

STATE OF LOUISIANA * NO. 2024-KA-0737

VERSUS * COURT OF APPEAL HOWARD E. BLUE * FOURTH CIRCUIT * STATE OF LOUISIANA *******

APPEAL FROM CRIMINAL DISTRICT COURT ORLEANS PARISH NO. 553-343, SECTION “G” Honorable Nandi Campbell ****** Judge Monique G. Morial ****** (Court composed of Judge Joy Cossich Lobrano, Judge Sandra Cabrina Jenkins, Judge Monique G. Morial)

LOBRANO, J., CONCURS IN THE RESULT JENKINS, J., CONCURS IN RESULT ONLY

JASON R. WILLIAMS DISTRICT ATTORNEY PARISH OF ORLEANS

Brad Scott Zachary M. Phillips ASSISTANT DISTRICT ATTORNEY 619 S. White Street New Orleans, LA 70119

COUNSEL FOR PLAINTIFF/APPELLEE

Holli Herrle-Castillo LOUISIANA APPELLATE PROJECT P. O. Box 2333 Marrero, LA 70073-2333

COUNSEL FOR DEFENDANT/APPELLANT

AFFIRMED AUGUST 21, 2025 Defendant, Howard E. Blue, (“Defendant”), appeals his June 27, 2024

MGM conviction for aggravated crime against nature, in violation of La. R.S.

14:89.1(A)(2). For the following reasons, we affirm Defendant’s conviction and

sentence.

Statement of the Case

Defendant was arrested on October 1, 2021 for crimes committed on or

about September 20, 2021. On February 22, 2022, the State of Louisiana charged

Defendant with one count of aggravated crime against nature pursuant to La. R.S.

14:89.1(A)(2). Defendant pled not guilty on March 9, 2022. A jury trial

commenced on June 25, 2024. During the trial, when called to testify, the nine-

year old victim1 initially refused to enter the courtroom. Although the State called

the victim to the stand twice, she failed to appear. Consequently, the trial court

dismissed the jury for the day. The defense then moved for a mistrial. The next

1 The statute requires proof that the defendant committed a prohibited sexual act upon a minor

under the age of eighteen, known by the defendant to be within the kinship degree described in La. R.S. 14:89.1(A)(2), and, for the enhanced sentencing under La. R.S. 14:89.1(C)(2) to apply, that the victim was under the age of thirteen at the time of the act. The State’s evidence proved each element relative to the child victim in this case and is not at issue.

1 morning, the victim appeared ready to testify at trial, yet the court declared a

mistrial. The State sought an emergency writ application with this Court and an

automatic stay pursuant to La. C.Cr.P. art. 775.1.2 In case number 2024-0374, this

Court denied the State’s emergency writ application. However, in 2024-00826, the

Louisiana Supreme Court granted the State’s emergency writ application. The

Supreme Court reversed the ruling of the trial court and remanded for further

proceedings.

Trial re-commenced on June 27, 2024, and the victim testified. At the

conclusion of trial, the jury found Defendant guilty of the charged crime. After

waiving all sentencing delays, the trial court sentenced Defendant to the mandatory

minimum sentence of twenty-five (25) years at hard labor on August 15, 2024.

During the sentencing hearing, the trial court also denied Defendant’s motion for

new trial and granted Defendant’s motion for appeal. This appeal followed.

Facts

On or about September 19, 2021, the then seven-year old victim, and her

younger brother were picked up at their home by the Defendant for an overnight

visit. The next day the victim reported that while visiting with Defendant, she went

into a bedroom with Defendant to play a game. Shortly thereafter, Defendant

pinched her genital area, or “noonie,” with two hands underneath her clothes and

underwear while she was sitting on his bed. The victim also reported that

2 La. C.Cr. P. art. 775.1 provides: If a judge orders a mistrial, then upon motion of either the state

or the defendant, the court shall order an automatic twenty-four-hour stay of all proceedings in which either the state or the defendant may take an emergency writ application to the appropriate reviewing courts with appellate jurisdiction, including the Louisiana Supreme Court.

2 Defendant stopped touching her, and pretended to watch television when Carol

Oribio entered the bedroom. After the alleged assault occurred, the victim

informed Defendant that she would tell her mother about the incident. She also

reported that Defendant became angry and slapped her hard on the leg, making her

cry. The victim ran into the kitchen and first reported the alleged assault to Ms.

Oribio. She indicated that Ms. Oribio did not believe her. When the children

returned home, the victim told her mother (“Mother”), that Defendant had touched

her; unsure of how to report the alleged assault her Mother3 called 911.

Sergeant Ron Howard was dispatched to Mother’s residence and took her

statement, but did not interview the victim. After taking Mother’s statement,

Sergeant Howard scheduled a forensic interview for the victim per New Orleans

Police Department (“NOPD”) procedure at the Child Advocacy Center. During

the course of his investigation, Sergeant Howard interviewed Mother, Carol

Oribio, reviewed the footage of the forensic interview, but did not interview

Defendant. The victim sat for a forensic interview with Tayla Oliver on or about

September 23, 2021, at the New Orleans Child Advocacy Center. During the

interview, the victim disclosed sexual abuse, and also identified a photograph of

Defendant, signed, and dated it. Sergeant Howard then sought an arrest warrant4

for Defendant which was issued on September 25, 2021.

3 In accordance with Ls. R.S. 46:1844(W)(1)(a), we will refer to the victim’s mother as “Mother”

to protect the victim’s identity. 4 We note, the arrest warrant was issued for sexual battery pursuant to La. R.S. 14:43.1.

3 Errors Patent

In accordance with La. C.Cr.P. art. 920, all appeals are reviewed for errors

patent. After a review of the record, we have detected none.

Discussion

Defendant alleges three assignments of error: (1) the trial court erred in

dismissing a juror ex-parte; (2) Defendant’s motion for mistrial should not have

been reversed by the Louisiana State Supreme Court; (3) and the evidence

submitted at trial was insufficient to support Defendant’s conviction.

Assignment of error number three: insufficiency of the evidence

Defendant argues there was insufficient evidence to support his conviction

for aggravated crime against nature because it was based solely on the conflicting,

uncorroborated and implausible testimony of the victim. When appellate courts

review the sufficiency of the evidence to support a conviction, they apply the

standard enunciated in Jackson v. Virginia, 443 U.S. 307, 99 S.Ct. 2781, 61

L.Ed.2d 560 (1979). State v. Dukes, 19-0172, p.7 (La. App. 4 Cir. 10/2/19), 281

So.3d 745, 752. Under the Jackson standard, the court must determine whether the

evidence, viewed in the light most favorable to the prosecution, was sufficient to

support a rational trier of fact’s finding that all of the elements of a crime were

proven beyond a reasonable doubt. Id. See also State v. Tate, 01-0658, p. 4 (La.

5/20/03), 851 So.2d 921, 928.

The appellate court must review the record in its entirety. State v. Mussall,

523 So.2d 1305, 1310 (La. 1988). “If rational triers of fact could disagree as to the

4 interpretation of the evidence, the rational trier’s view of all the evidence most

favorable to the prosecution must be adopted. Id. Defendant was charged with

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