State of Louisiana v. James Cody McMahon

CourtLouisiana Court of Appeal
DecidedSeptember 21, 2022
Docket54,740-KA
StatusPublished

This text of State of Louisiana v. James Cody McMahon (State of Louisiana v. James Cody McMahon) 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. James Cody McMahon, (La. Ct. App. 2022).

Opinion

Judgment rendered September 21, 2022. Application for rehearing may be filed within the delay allowed by Art. 922, La. C. Cr. P.

No. 54,740-KA

COURT OF APPEAL SECOND CIRCUIT STATE OF LOUISIANA

*****

STATE OF LOUISIANA Appellee

versus

JAMES CODY MCMAHON Appellant

Appealed from the Fourth Judicial District Court for the Parish of Ouachita, Louisiana Trial Court No. 19-CR4712

Honorable Hamilton Stephens Winters, Judge

LOUISIANA APPELLATE PROJECT Counsel for Appellant By: Edward Kelly Bauman

ROBERT STEPHEN TEW Counsel for Appellee District Attorney

JUSTIN A. WOOLEY Assistant District Attorney

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

This case arises out of the Fourth Judicial District Court, Ouachita

Parish, Louisiana. James Cody McMahon was charged and unanimously

convicted in violation of La. R.S. 14:91.5, unlawful use of a social

networking site. McMahon appealed, and this Court vacated his sentence

and remanded for resentencing. On remand, McMahon was sentenced to his

original sentence of three years at hard labor without probation, parole, or

suspension of sentence. He now argues La. R.S. 14:91.5 is unconstitutional

and his Fourth and Fourteenth Amendment rights were violated. For the

following reasons, we affirm.

FACTS

McMahon was charged by amended bill of information of one count

of unlawful use of a social networking site in violation of La. R.S. 14:91.5.

At the time of his charge, he was on supervised probation for an indecent

behavior with a juvenile conviction. During a visit with his probation

officer, Amanda Peoples, he was asked to submit to a random drug test.

Before the drug test, he was asked to submit his cell phone for a search.

Officers found applications for Facebook, Snapchat, Twitter, and Instagram

on his cell phone. Officers then requested a search warrant to search

McMahon’s phone, including social media accounts, emails, and chats on

any social media accounts.

On February 10, 2020, McMahon filed a motion to suppress prior to

the start of voir dire. He argued his phone “was seized and searched without

a warrant and without probable cause or reasonable suspicion in violation of

the Fourth Amendment” and his consent to search the phone was coerced.

The parties agreed that the motion would be heard on the merits. During trial, Deputy Peoples testified that as a condition of

McMahon’s probation, he could not have social media accounts. She stated

that she reminded him of this when she would visit his home but did not

personally review this condition with him in 2016 when he was convicted.

Deputy Peoples testified that on August 6, 2019, she decided to give

McMahon a random drug screen. She stated that when he was going

through the metal detector, he had to place his cell phone on the counter.

She testified that when he set his cell phone down, she told him she would

like to look at it. She stated that she asked him if there was anything on it he

was not supposed to have, he said no, and she had him unlock the passcode

on the cell phone. She stated that he did not hesitate to put the passcode into

the phone.

Deputy Peoples testified that after McMahon typed the passcode, he

handed her his cell phone, she looked at the phone, and it was “quite

obvious” that he had Facebook and Snapchat icons. She testified that when

she asked McMahon if he knew he was not supposed to have social media

accounts, he said he did know that.

Deputy Stacy Morrison testified that she is in charge of sex offender

registrations for Ouachita Parish. She stated that individuals who come

through her office are required to fill out a sex offender contract, which

outlines rules and prohibits the use of social media. She stated that when an

offender first comes to her office, she explains the rules. Deputy Morrison

was shown a copy of McMahon’s sex offender contract and verified that he

initialed the bottom of every page, signifying that he understood all the

rules.

2 Officer Corey Bennett testified that he is a supervisor for probation

and parole for the State of Louisiana. He stated that he originally set up

McMahon’s case in 2016 and supervised him from May of 2017 until

sometime in 2019. He testified that he reviewed the rules of probation with

McMahon. He stated that the rules include a prohibition on social media use

and provide for an inspection of computers and electronic devices. He

testified that in sex offender cases, cell phones are randomly checked.

Officer Bennett stated that McMahon could have refused the search and put

his cell phone in his vehicle.

On February 11, 2020, while the jury deliberated, the trial court

denied McMahon’s motion to suppress. McMahon was found guilty by a

unanimous jury of unlawful use of a social networking site. He was

sentenced to three years at hard labor. McMahon appealed. His sentence

was vacated, and his case was remanded on July 21, 2021.1 In that per

curiam opinion, McMahon’s sentence was vacated and the matter remanded

for further proceedings because the trial court failed to rule on his motion for

post-verdict judgment of acquittal and motion in arrest of judgment prior to

sentencing. On July 28, 2021, the trial court held a hearing to correct the

minutes. The trial court stated that McMahon’s motion for post-verdict

judgment of acquittal and motion in arrest of judgment had been ruled on.

The trial court supplemented the record with transcripts of the sentencing

where both motions were addressed and ordered the minutes be corrected to

reflect the disposition of the motions.

1 State v. McMahon, 54,172, (La. App. 2 Cir. 7/21/21) 2021 WL 3073069. 3 McMahon’s resentencing hearing was held on December 30, 2021.

At that hearing, the trial court discussed the remand from this Court. The

trial court stated and defense counsel agreed that the motions had been ruled

upon or waived at the prior sentencing. McMahon agreed on the record that

his motion for post-verdict judgment of acquittal had been ruled upon. He

then waived his motion in arrest of judgment and motion for new trial.

McMahon stated he believed these motions were taken care of prior to his

original sentencing. The trial court sentenced McMahon to his original

sentence of three years. McMahon now appeals.

DISCUSSION

Constitutionality of La. R.S. 14:91.5

McMahon argues that the trial court erred in denying his pro se

motion in arrest of judgment and in ruling La. R.S. 14:91.5 is constitutional.

He points out that in Packingham v. North Carolina, -- U.S. --, 137 S. Ct.

1730, 198 L. Ed. 2d 273 (2017), the Supreme Court held that a similar North

Carolina statute was unconstitutional.

McMahon argues that La. R.S. 14:91.5 is unconstitutional because it

infringes on his First Amendment right to freedom of speech. He asserts

that an absolute restriction on his internet access may derail his chances of

seeking gainful employment or maintaining networking capabilities to keep

employment. He argues that the statute, as written, is not narrowly written

to prevent illicit communications between sex offenders and minors but is a

blanket restriction on First Amendment rights. He requests the trial court be

reversed and La. R.S. 14:91.5 be declared unconstitutional.

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582 U.S. 98 (Supreme Court, 2017)
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246 So. 3d 672 (Louisiana Court of Appeal, 2018)
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Bluebook (online)
State of Louisiana v. James Cody McMahon, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-louisiana-v-james-cody-mcmahon-lactapp-2022.