State Of Louisiana v. Jonathan Richardson

CourtLouisiana Court of Appeal
DecidedMay 11, 2020
Docket2019KA1161
StatusUnknown

This text of State Of Louisiana v. Jonathan Richardson (State Of Louisiana v. Jonathan Richardson) 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. Jonathan Richardson, (La. Ct. App. 2020).

Opinion

STATE OF LOUISIANA

COURT OF APPEAL

FIRST CIRCUIT

2019 KA 1161

VERSUS

V JONATHAN S. RICHARDSON

Judgment Rendered: MAY 1 12020

On Appeal from the Twenty -Second Judicial District Court In and for the Parish of Washington State of Louisiana Trial Court No. 18- CR10- 138328

The Honorable William H. Burris, Judge Presiding

Lieu T. Vo Clark Attorney for Defendant/Appellant, Mandeville, Louisiana Jonathan S. Richardson

Warren L. Montgomery Attorneys for Appellee, District Attorney State of Louisiana J. Bryant Clark Assistant District Attorney Covington, Louisiana

BEFORE: HIGGINBOTHAM, PENZATO, AND LANIER, JJ. PENZATO, I

The defendant, Jonathan S. Richardson, was charged by felony bill of

information with failure to comply with provisions of supervised release, in

violation of La. R.S. 15: 561. 7( A). See also La. R.S. 15: 561. 2 and La. R.S.

15: 561. 5. He pled not guilty. After a trial by jury, the defendant was found guilty

as charged. The trial court denied the defendant' s amended motion for post -verdict

judgment of acquittal and amended motion for new trial but granted the

defendant' s motion to quash the habitual offender bill of information filed by the

State pursuant to La. R. S. 15: 529. 1. The defendant was sentenced to four years

imprisonment at hard labor without the benefit of probation, parole, or suspension

of sentence. The defendant now appeals, assigning error to the sufficiency of the

evidence to support the verdict and to the trial court' s denial of his amended

motion for post -verdict judgment of acquittal. For the following reasons, we

reverse the conviction and vacate the sentence.

STATEMENT OF FACTS

On March 31, 2018, Agent Kevin Kulivan, a sex offender specialist of the

Department of Public Safety and Corrections assigned to monitor the defendant

upon his release from prison, conducted a field visit at the defendant' s residence.

At trial, Agent Kulivan testified that due to the defendant' s prior sex offenses,

thirty counts of distribution of child pornography, his target for the field visit was a

computer-related search in order to prevent any further offenses. Upon his arrival,

Agent Kulivan asked to see the defendant' s computer, and the defendant complied.

Agent Kulivan noted that the computer, a laptop, had plug- in devices and flash

drives attached. As Agent Kulivan perused the photographs on the computer, he

noticed an article, saved on one of the attached flash drives, entitled, " Why do girls

become so f ----- g horrible when they grow up?". The article featured side- by- side

images of an adult female and a juvenile girl with an annotation, in part, describing

2 little girls as having " innocent, virginal, angelic looks," while describing adult girls

as " overly sexual, bodies look like pornstars."

The article prompted Agent Kulivan to continue searching the computer.

Agent Kulivan attempted to access the internet search history to see when and from

where the article was obtained, but the history list was blank. The defendant

informed Agent Kulivan that the private browsing feature was enabled and

prevented the web browser from saving any history. Thus, Agent Kulivan was

unable to view any search or content history for the computer or its attachments.

Agent Kulivan reported his findings to his supervisor, and the defendant was

arrested for the instant offense on April 2, 2018.

SUFFICIENCY OF THE EVIDENCE

In a combined argument in support of both assignments of error, the

defendant contends that the State failed to prove beyond a reasonable doubt that he

had been convicted of a qualifying predicate felony that would subject him to the

conditions of supervised release. The defendant contends that the State offered

only the " equivocating" testimony of Agent Kulivan without any documentary

proof of a predicate. The defendant notes that Agent Kulivan initially testified that

the defendant was subject to monitoring pursuant to supervised release because he

had a prior sex offense in which the victim was under thirteen. However, when

asked specifically the crime for which defendant was convicted, he responded

t]hirty counts of distribution of child pornography." The defendant notes that the

State failed to offer a bill of information and certified minutes to prove that he was

legally required to be subjected to supervised release pursuant to La. R.S. 15: 561 et

seq. The defendant further contends that his pre -sentence investigation report

shows that he is factually innocent of the instant offense, claiming that his sole

felony conviction listed therein was not for a sex offense involving a victim under

3 the age of thirteen.' Thus, the defendant argues that the trial court should have

granted his amended motion for post -verdict judgment of acquittal and that his

conviction should be reversed.

The standard of review for the sufficiency of the evidence to uphold a

conviction is whether, 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 beyond a reasonable doubt. Jackson v. Virginia, 443 U.S. 307, 319, 99 S. Ct.

2781, 2789, 61 L.Ed.2d 560, 573 ( 1979). See also La. Code Crim. P. art. 821( B);

State v. Ordodi, 2006- 0207 ( La. 11/ 29/ 06), 946 So. 2d 654, 660; State v. Jackson,

2018- 0261 ( La. App. 1st Cir. 11/ 2/ 18), 265 So. 3d 928, 933, writ denied, 2018-

1969 ( La. 4/ 22/ 19), 268 So. 3d 304. The Jackson standard of review, incorporated

in Article 821, is an objective standard for testing the overall evidence, both direct

and circumstantial, for reasonable doubt. State v. Cole, 2019- 0033 ( La. App. 1st

Cir. 9/ 27/ 19), 288 So. 3d 146, 156.

Circumstantial evidence consists of the proof of collateral facts and

circumstances from which the existence of the main fact may be inferred according

to reason and common experience. State v. Duncan, 2002- 0509 ( La. App. 1 st Cir.

9/ 27/ 02), 835 So. 2d 623, 630, writ denied, 2003- 0600 ( La. 3/ 12/ 04), 869 So. 2d

812. When analyzing circumstantial evidence, La. R.S. 15: 438 provides that the

fact finder must be satisfied that the overall evidence excludes every reasonable

hypothesis of innocence. See State v. Patorno, 2001- 2585 ( La. App. 1st Cir.

6/ 21/ 02), 822 So. 2d 141, 144. When a case involves circumstantial evidence and

the trier of fact reasonably rejects the hypothesis of innocence presented by the

defense, that hypothesis falls, and the defendant is guilty unless there is another

hypothesis which raises a reasonable doubt. State v. Dyson, 2016- 1571 ( La. App.

1 This document was prepared subsequent to the trial and filed in the record following sentencing. Despite defendant' s contention, it is not evidence and, therefore, ultimately not considered by this court.

M 1st Cir. 6/ 2/ 17), 222 So. 3d 220, 228, writ denied, 2017- 1399 ( La. 6/ 15/ 18), 257

So. 3d 685.

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Related

Jackson v. Virginia
443 U.S. 307 (Supreme Court, 1979)
State v. Lawrence
925 So. 2d 727 (Louisiana Court of Appeal, 2006)
State v. Bindom
410 So. 2d 749 (Supreme Court of Louisiana, 1982)
State v. Marshall
943 So. 2d 362 (Supreme Court of Louisiana, 2006)
State v. Wallace
788 So. 2d 578 (Louisiana Court of Appeal, 2001)
State v. Broussard
819 So. 2d 1141 (Louisiana Court of Appeal, 2002)
State v. Duncan
835 So. 2d 623 (Louisiana Court of Appeal, 2002)
State v. Patorno
822 So. 2d 141 (Louisiana Court of Appeal, 2002)
State v. Ordodi
946 So. 2d 654 (Supreme Court of Louisiana, 2006)
State v. Maxwell
83 So. 3d 113 (Louisiana Court of Appeal, 2011)
State of Louisiana v. Gerald W. Dahlem
197 So. 3d 676 (Supreme Court of Louisiana, 2016)
State v. Williams
131 So. 3d 33 (Supreme Court of Louisiana, 2013)
State v. Dahlem
148 So. 3d 591 (Louisiana Court of Appeal, 2014)
State v. Dyson
222 So. 3d 220 (Louisiana Court of Appeal, 2017)
State v. Lowrey
228 So. 3d 779 (Louisiana Court of Appeal, 2017)
State v. Trosclair
89 So. 3d 340 (Supreme Court of Louisiana, 2012)

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