State of Louisiana v. James E. Ramsdell

CourtLouisiana Court of Appeal
DecidedOctober 6, 2010
DocketKA-0009-1510
StatusUnknown

This text of State of Louisiana v. James E. Ramsdell (State of Louisiana v. James E. Ramsdell) 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 E. Ramsdell, (La. Ct. App. 2010).

Opinion

STATE OF LOUISIANA COURT OF APPEAL, THIRD CIRCUIT

09-1510

STATE OF LOUISIANA

VERSUS

JAMES E. RAMSDELL

**********

APPEAL FROM THE THIRTY-SIXTH JUDICIAL DISTRICT COURT PARISH OF BEAUREGARD, NO. CR974-07 HONORABLE C. KERRY ANDERSON, DISTRICT JUDGE

MARC T. AMY JUDGE

Court composed of John D. Saunders, Marc T. Amy, and Elizabeth A. Pickett, Judges.

CONVICTIONS AFFIRMED. ARMED ROBBERY SENTENCE AFFIRMED AS AMENDED.

David W. Burton District Attorney Richard A. Morton Assistant District Attorney Post Office Box 99 DeRidder, LA 70634 (337) 463-5578 COUNSEL FOR APPELLEE: State of Louisiana

Edward Kelly Bauman Louisiana Appellate Project Post Office Box 1641 Lake Charles, LA 70602-1641 (337) 491-0570 COUNSEL FOR DEFENDANT/APPELLANT: James E. Ramsdell AMY, Judge.

The defendant was convicted of first degree murder, conspiracy to commit first

degree murder, armed robbery, aggravated burglary, theft of a firearm, and theft of

movable property over five hundred dollars. The trial court vacated the defendant’s

aggravated burglary conviction, and he was sentenced on the remaining charges. The

defendant appeals his armed robbery conviction as a violation of the prohibition

against double jeopardy. Further, he challenges the sufficiency of the evidence used

to convict him of first degree murder. The defendant also argues that the trial court

erred in failing to grant several motions for mistrial. For the following reasons, we

affirm the defendant’s convictions, and affirm the defendant’s sentence for armed

robbery as amended.

Factual and Procedural Background

This matter involves the October 9, 2007, shooting death of John “Jack”

Mayeaux. It is alleged that the defendant, James E. Randall, shot and killed Mr.

Mayeaux, and then, with the help of two accomplices, Terry Clarkson and D.B.1, stole

some of the victim’s movable property, including a four-wheeler, money, several

guns, ammunition, and tools.

The defendant was indicted by a grand jury with first degree murder, a

violation of La.R.S. 14:30; conspiracy to commit first degree murder, violations of

La.R.S. 14:26 and 14:30; armed robbery, a violation of La.R.S. 14:64; aggravated

burglary, a violation of La.R.S. 14:60; theft of a firearm, a violation of La.R.S.

14:67.15; and theft of movable property over $500.00, a violation of La.R.S.

14:67(B)(1). Following a jury trial, the defendant was found guilty as charged.

1 In accordance with Uniform Rules, Courts of Appeal, 5-2, initials will be used to “ensure the confidentiality of a minor who is a party to or whose interests are the subject matter in the proceedings[.]” Following his convictions, the defendant filed a Motion to Set Aside Verdict

of Jury, arguing that his convictions for first degree murder in addition to armed

robbery and armed burglary violated the prohibition against double jeopardy. The

trial court granted the motion and vacated his conviction for aggravated burglary.

The defendant was subsequently sentenced on the remaining convictions as follows:

life imprisonment without the benefit of parole, probation or suspension of sentence

for first degree murder; thirty years imprisonment at hard labor for criminal

conspiracy to commit first degree murder; one hundred four years imprisonment at

hard labor without the benefit of parole, probation or suspension of sentence for

armed robbery; ten years imprisonment at hard labor without benefit of parole,

probation or suspension of sentence, and a fine of $1,000.00 for theft of firearms, and;

ten years imprisonment at hard labor for theft of movable property over $500.00. The

trial court ordered the sentences to run consecutively.

The defendant appeals, asserting that the trial court erred in failing to grant his

Motion to Set Aside Verdict of Jury regarding his armed robbery conviction, and in

denying his motions for mistrial. The defendant also questions the sufficiency of the

evidence used to convict him of first degree murder.

Discussion

Errors Patent

In accordance with La.Code Crim.P. art. 920, all appeals are reviewed for

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

patent regarding the sentence imposed for armed robbery.

The trial court sentenced the defendant to serve one hundred four years

imprisonment at hard labor for the armed robbery conviction. At his hearing on the

2 Motion to Set Aside the Jury Verdict, the trial court stated that the penalty for “armed

robbery with a firearm carries a maximum of a 104 year sentence with the 99 year

plus the five-year firearm enhancement.”

Under La.R.S. 14:64, the maximum sentence for armed robbery is ninety-nine

years imprisonment at hard labor. However, under La.R.S. 14:64.3, “[w]hen the

dangerous weapon used in the commission of the crime of armed robbery is a firearm,

the offender shall be imprisoned at hard labor for an additional period of five years

without benefit of parole, probation, or suspension of sentence.” To invoke the

provisions of La.R.S. 14:64.3, the statute must be charged in the bill of information

or indictment. State v. Daniels, 03-1621 (La.App. 3 Cir. 5/12/04), 873 So.2d 822, writ

denied, 04-1802 (La.11/24/04), 888 So.2d 227.

In this case, the State did not cite La.R.S. 14:64.3 nor set forth that the crime

of armed robbery was committed with a firearm in the indictment. As noted above,

the first and only time enhancing the armed robbery sentence was mentioned was by

the trial judge, not the State, during the defendant’s post-verdict motion hearing.

Since the trial court cannot trigger enhancement on its own, we find that the trial

court lacked authority to impose the enhanced sentence. The maximum sentence for

armed robbery in this present matter is ninety-nine years imprisonment at hard labor.

La.R.S. 14:64. As such, the trial court’s one hundred four years sentence was

illegally excessive. State v. Jacobs, 08-702 (La.App. 3 Cir. 2/4/09), 2 So.3d 1289.

Accordingly, we reverse the trial court’s inclusion of the five year enhancement and

otherwise affirm the defendant’s sentence for armed robbery as amended.

3 Sufficiency of the Evidence

The defendant argues that the evidence adduced at trial was insufficient to

support his first degree murder conviction. In State v. Freeman, 01-997, pp. 2-3

(La.App. 3 Cir. 12/12/01), 801 So.2d 578, 580, a panel of this court discusses the

standard for insufficiency claims as follows:

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 (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 credibilities of the witnesses, and therefore, the appellate court should not second guess the credibility determinations of the trier of fact beyond the sufficiency evaluations under the Jackson standard of review. See Graffagnino, 436 So.2d at 563, citing State v. Richardson, 425 So.2d 1228 (La.1983).

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Blockburger v. United States
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796 So. 2d 649 (Supreme Court of Louisiana, 2001)
State v. Doughty
379 So. 2d 1088 (Supreme Court of Louisiana, 1980)
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State v. Clark
780 So. 2d 418 (Louisiana Court of Appeal, 2000)
State v. Duncan
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State v. Goodley
820 So. 2d 478 (Supreme Court of Louisiana, 2002)
State v. Moody
393 So. 2d 1212 (Supreme Court of Louisiana, 1981)
State Ex Rel. Adams v. Butler
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State v. Bernard
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State v. Williams
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State of Louisiana v. James E. Ramsdell, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-louisiana-v-james-e-ramsdell-lactapp-2010.