State of Louisiana v. Jason Lee Short

CourtLouisiana Court of Appeal
DecidedMay 16, 2007
DocketKA-0006-1451
StatusUnknown

This text of State of Louisiana v. Jason Lee Short (State of Louisiana v. Jason Lee Short) 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. Jason Lee Short, (La. Ct. App. 2007).

Opinion

STATE OF LOUISIANA COURT OF APPEAL, THIRD CIRCUIT

06-1451

STATE OF LOUISIANA

VERSUS

JASON LEE SHORT

********** APPEAL FROM THE SEVENTH JUDICIAL DISTRICT COURT PARISH OF CONCORDIA, DOCKET NO. 05-0736 HONORABLE LEO BOOTHE, DISTRICT JUDGE **********

SYLVIA R. COOKS JUDGE

**********

Court composed of Sylvia R. Cooks, John D. Saunders and Michael G. Sullivan, Judges.

AFFIRMED.

J. Rodney Messina 256 East Boulevard Baton Rouge, LA 70802 (225) 343-9422 COUNSEL FOR DEFENDANT/APPELLANT: Jason Lee Short

Bradley R. Burget, Assistant District Attorney Seventh Judicial District 4001 Carter Street, Suite 9 Vidalia, LA 71373 (318) 336-5526 COUNSEL FOR APPELLEE: State of Louisiana COOKS, Judge.

FACTS AND PROCEDURAL HISTORY

In the early morning hours of April 5, 2005, Jason Lee Short and Joseph

Loncar allegedly left Short’s residence to rob a crack dealer. En route, they spotted

the victim, Richard Cupstid, walking down Roundtree Road in Concordia Parish.

Cupstid was struck by Short’s vehicle. He was then beaten and robbed. Short and

Loncar then got back in the vehicle and exited Roundtree Road onto U.S. Highway

84/65. Within minutes, they re-entered Roundtree Road and headed back to Short’s

residence, where they again saw the victim. Cupstid was then shot in the head at

close range and left on the side of the roadway. Cupstid died as a result of his

injuries.

On June 1, 2005, the State filed an indictment charging the Defendant, Jason

Lee Short, with second degree murder, in violation of La.R.S. 14:30.1. A jury trial

was held and Defendant was found guilty of second degree murder. Defendant was

subsequently sentenced to life imprisonment without benefit of probation, parole, or

suspension of sentence.

Defendant is now before the court asserting three assignments of error.

Defendant contends the trial court erred in denying his objection to the hearsay

statements made by an unavailable co-perpetrator, the trial court erred in denying his

motion for mistrial, and the trial court erred in allowing Investigator Jimmy Darden

to testify as an expert without being tendered as such.

ASSIGNMENT OF ERROR NO. 1

In his first assignment of error, Defendant contends the trial court erred in

denying his objection to the hearsay statements made by the unavailable co-

perpetrator Joseph Loncar. These statements were introduced into evidence via the

-1- testimony of Angela Mapp and Keysha Freeman, which Defendant argues is in direct

violation of his Sixth Amendment right.

On May 22, 2006, Defendant filed a Motion in Limine, seeking to prohibit the

State from eliciting testimony from several named witnesses regarding statements

Joseph Loncar made to them about the events on the night of April 5, 2005. At a

hearing, the trial court granted the motion “to the extent that any direct criminal

activity will be excluded.” The trial court later clarified that if, during their

testimony, witnesses testified regarding what Loncar said the Defendant did, that

testimony would not be admissible.

At trial, Loncar exercised his Fifth Amendment privilege against self-

incrimination and was declared unavailable to testify. The State later called Keysha

Freeman and Angela Mapp to testify. Freeman was questioned as follows:

Q. Did Mr. Loncar make any statements to you?

A. He told me - -

Q. Just, did he make some statements to you?
A. Yes, sir.
Q. Did he indicate to you that he had robbed somebody?
Q. Did he indicate to you that he robbed somebody with a gun?

A. I’m not sure if he robbed him with a gun, but I remember hearing him saying something about pistol whipping.

Q. Did he pistol whip somebody?
A. He said that a pistol whipping took place.
Q. Now, did he tell you how this occurred whether he was in a vehicle or not?

-2- Q. Did he tell you whether he was the driver of the vehicle or passenger of the vehicle?

A. He said he was on the passenger side.
Q. Did he tell you that someone may have been run over?
Q. Did he tell you whether or not this occurred before or after the robbery?

....

Q. Did Mr. Loncar indicate whether or not the running over of somebody occurred prior to the robbery or after the robbery?

A. I believe it was after.
Q. After?
Q. According to what Mr. Loncar told you?
Q. Did Mr. Loncar tell you whether or not he shot anyone?
A. No, sir.
Q. He didn’t tell you anything or he told you he did not shoot someone?
A. He told me he did not shoot anyone.
Q. The only information you have is what Mr. Loncar told you?

Angela Mapp was then questioned as follows:

Q. Did Mr. Loncar eventually tell you why he wanted you to come to Vidalia and pick him up?

A. Yes, sir, he did.
Q. Did he tell you whether or not he was involved in a robbery?
A. Yes, he did.

-3- Q. Did he tell you that he robbed a person?

Q. Did he indicate to you whether or not he used a gun in the crime that he committed of robbery?

Q. Did he tell you whether or not he beat the person that he robbed?
Q. Did he tell you that there was a vehicle used in this crime?

Q. Did he tell you whether or not he was the driver or the passenger of this vehicle.

A. He said he was in the passenger’s side.
Q. Did he tell you whether or not somebody was shot?
Q. Did he indicate whether or not he shot that person?
A. He said he did not shoot this person.

Q. Did he indicate whether or not the robbery and the beating that he inflicted on this person occurred before or after this person was run over?

A. He said before.
Q. He said a robbery occurred?
A. A robbery occurred -- well, a beating, a robbery and then the boy got run over.
Q. And the shooting occurred after that?

Defendant asserts for any statement Loncar made to be admissible at trial, the

statement must qualify as an exception to the hearsay rule set out in La.Code Evid.

art. 804(B). Defendant argues none of the exceptions in Article 804(B) were met.

-4- Defendant additionally asserts the statements made by Loncar were not statements

against interest, as alleged by the State, because they were statements against the

interests of the Defendant and not those of Loncar. The Defendant then asserts the

statements made by Loncar were testimonial in nature; thus, falling under the purview

of Crawford v. Washington, 541 U.S. 36, 124 S.Ct. 1354 (2004).

Louisiana Code of Evidence Article 804 provides, in pertinent part, as follows:

B. Hearsay exceptions. The following are not excluded by the hearsay rule if the declarant is unavailable as a witness:

(3) Statement against interest.

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State of Louisiana v. Jason Lee Short, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-louisiana-v-jason-lee-short-lactapp-2007.