State of Louisiana v. Joseph Barton

CourtLouisiana Court of Appeal
DecidedFebruary 15, 2023
DocketKA-0022-0642
StatusUnknown

This text of State of Louisiana v. Joseph Barton (State of Louisiana v. Joseph Barton) 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. Joseph Barton, (La. Ct. App. 2023).

Opinion

STATE OF LOUISIANA COURT OF APPEAL, THIRD CIRCUIT

22-642

STATE OF LOUISIANA

VERSUS

JOSEPH BARTON

**********

APPEAL FROM THE TWELFTH JUDICIAL DISTRICT COURT PARISH OF AVOYELLES, NO. 2020-CR-223147 HONORABLE WILLIAM J. BENNETT, DISTRICT JUDGE

CHARLES G. FITZGERALD JUDGE

Court composed of Candyce G. Perret, Charles G. Fitzgerald, and Guy E. Bradberry, Judges.

AFFIRMED. Peggy J. Sullivan Louisiana Appellate Project Post Office Box 1481 Monroe, Louisiana 71210 (318) 855-6038 Counsel for Defendant/Appellant: Joseph Barton

Charles Riddle District Attorney Twelfth Judicial District Anthony F. Salario Elizabeth E. Williams Assistant District Attorneys Post Office Box 1200 Marksville, Louisiana 71351 (318) 240-7123 Counsel for Appellee: State of Louisiana FITZGERALD, Judge.

Defendant, Joseph Barton, appeals his conviction and sentence for armed

robbery with a firearm.

PROCEDURAL HISTORY

In September 2020, Defendant was charged by bill of information with armed

robbery while armed with a firearm. Prior to trial, Defendant filed a motion to recuse

the district attorney. This motion was denied by the trial court.

The matter proceeded to jury trial in March 2022. At the conclusion of trial,

the jury unanimously found Defendant guilty as charged. A few days later,

Defendant filed a motion for judgment notwithstanding the verdict. And a few

weeks after that, Defendant filed a motion for post-verdict judgment of acquittal.

Both motions were denied prior to the imposition of sentence.

In May 2022, the trial court sentenced Defendant to forty years at hard labor

for the armed-robbery conviction and five years at hard labor to be served

consecutively for the firearm enhancement. Both sentences were ordered to be

served without benefit of parole, probation, or suspension of sentence. Defendant,

in turn, filed a motion to reconsider sentence. This motion was also denied by the

trial court. Defendant now appeals his conviction and sentence.

On appeal, Defendant asserts four assignments of error:

1. The State failed to prove beyond a reasonable doubt [Defendant] was guilty of armed robbery. The victims of the robbery could not identify [Defendant]. The only identification of him as one of the suspects was by virtue of body language or the testimony of [Deondrake] Guillot, who was admittedly one of the suspects. No physical evidence tied [Defendant] to this offense.

2. The Trial Court erred in denying the Motion to Recuse the District Attorney in this matter. 3. The sentence imposed in this case was constitutionally excessive considering the facts and circumstances of the case and the background of [Defendant]. [Defendant] is 57 years old and the sentence of 45 years imposed in this case is effectively a life sentence. As such, it is unconstitutionally harsh and excessive. [Defendant] was employed, no one was physically harmed, no shots were fired, and a lesser sentence would not deprecate the seriousness of the offense.

4. Considering the excessive nature of the sentence in this case the Trial Court erred in denying the Motion to Reconsider Sentence in this case.

LAW AND ANALYSIS

I. 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 two

potential patent errors but neither requires correction.

First, the bill of information charges Defendant with “armed robbery; use of

a firearm; additional penalty,” citing La.R.S. 14:64.3. Louisiana Revised Statutes

14:64.3 provides an enhanced sentence for an offender who commits armed robbery

with a firearm. But the crime of armed robbery is defined by La.R.S. 14:64, and this

statute is not cited in the bill of information. Thus, we turn to La.Code Crim.P. art.

464, which concerns the nature and contents of an indictment. Article 464 states:

The indictment shall be a plain, concise, and definite written statement of the essential facts constituting the offense charged. It shall state for each count the official or customary citation of the statute which the defendant is alleged to have violated. Error in the citation or its omission shall not be ground for dismissal of the indictment or for reversal of a conviction if the error or omission did not mislead the defendant to his prejudice.

Here, Defendant does not assert that he was misled to his prejudice because

of the State’s failure to cite La.R.S. 14:64 in the bill of information. The error with

2 the bill of information is therefore harmless. See State v. Allen, 09-1281 (La.App. 3

Cir. 5/5/10), 36 So.3d 1091.

Second and finally, we address whether the trial court’s statement regarding

diminution of sentence was a ruling or an advisement. At the sentencing hearing,

the trial court stated that “[a]rmed robbery is a crime of violence; therefore, this

sentence is not subject to diminution for good behavior. This is not an enhanced

sentence.” The minutes of sentencing further provide as follows:

AS REQUIRED BY ARTICLE 890.1 OF CODE OF CRIMINAL PROCEDURE AND ARTICLE 894.1D OF THE CODE OF CRIMINAL PROCEDURE, THE COURT DESIGNATED THAT THE CRIME INVOLVED WAS A CRIME OF VIOLENCE OR ATTEMPTED CRIME OF VIOLENCE AS DEFINED OR “AS REQUIRED BY ARTICLE 890.1 OF THE CODE OF CRIMINAL PROCEDURE ENUMERATED IN R.S. 14:2 “13”, AND ALSO INFORMED THE DEFENDANT WHETHER, PURSUANT TO THE PROVISIONS OF R.S. 15:571.3, THE DEFENDANT’S SENTENCE WAS NOT SUBJECT TO DIMINUTION FOR GOOD BEHAVIOR, AND WHETHER THE SENTENCE IMPOSED WAS ENHANCED PURSUANT TO R.S. 15:529.1 ET SEQ[.]

Importantly, “Louisiana Code Criminal Procedure Article 890.1 was amended

in 2012 and no longer authorizes a trial court to deny or restrict diminution of

sentence for crimes of violence. 2012 La. Acts No. 160. Trial courts are no longer

required to advise defendants of whether their sentences are subject to diminution.”

State v. Watson, 21-725, pp. 7-8 (La.App. 3 Cir. 4/27/22), 338 So.3d 95, 100.

In Watson, the trial court stated that “[t]hese sentences are crimes of violence

and are not subject to diminution for good behavior, [and] these are not enhanced

sentences.” Id. The minutes of sentencing in that case reiterated the trial court’s

statement. On those facts, a different panel of this court concluded that the trial

court’s statement was merely advisory.

3 In our case, the relevant facts are substantially similar to those presented in

Watson. And like Watson, we conclude that the trial court’s statement regarding

diminution of sentence was an advisement. Thus, there is no patent error in this

instance.

II. First Assignment of Error

In his first assignment of error, Defendant claims that the State failed to prove

beyond a reasonable doubt that he was guilty of armed robbery with a firearm. He

specifically contends that he was not the perpetrator of this crime. Hence, Defendant

challenges the sufficiency of the evidence.

A sufficiency-of-the-evidence challenge is reviewed on appeal under the

standard set forth by Jackson v. Virginia, 443 U.S. 307, 99 S.Ct. 2781 (1979). In

that case, the United States Supreme Court explained that “the relevant question 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 beyond

a reasonable doubt.” Id.

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