State of Louisiana v. Joseph Peterson

CourtLouisiana Court of Appeal
DecidedJanuary 8, 2020
Docket2018-KA-1045
StatusPublished

This text of State of Louisiana v. Joseph Peterson (State of Louisiana v. Joseph Peterson) 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 Peterson, (La. Ct. App. 2020).

Opinion

STATE OF LOUISIANA * NO. 2018-KA-1045

VERSUS * COURT OF APPEAL JOSEPH PETERSON * FOURTH CIRCUIT * STATE OF LOUISIANA *******

CONSOLIDATED WITH: CONSOLIDATED WITH:

STATE OF LOUISIANA NO. 2018-KA-1046

VERSUS

JOSEPH PETERSON

APPEAL FROM 25TH JDC, PARISH OF PLAQUEMINES NO. 14-2838, DIVISION “B” Honorable Michael D. Clement, ****** JUDGE SANDRA CABRINA JENKINS ****** (Court composed of Judge Edwin A. Lombard, Judge Sandra Cabrina Jenkins, Judge Regina Bartholomew-Woods)

Charles Joseph Ballay, District Attorney 25TH JDC, PLAQUEMINES PARISH 102 Avenue G Belle Chasse, LA 70037 Pamela S. Moran, Assistant Attorney General 1885 North Third Street P. O. Box 94005 Baton Rouge, LA 70804—9005 COUNSEL FOR STATE OF LOUISIANA/APPELLEE Bruce G. Whittaker LOUISIANA APPELLATE PROJECT 1215 Prytania Street, Suite 332 New Orleans, LA 70130 COUNSEL FOR DEFENDANT/APPELLANT

AFFIRMED JANUARY 8, 2020 The defendant, Joseph Peterson, appeals his conviction for three counts of

aggravated incest, in violation of La. R.S. 14:78.1.1 The defendant assigns two

errors in this appeal, arguing that the evidence is insufficient to sustain the

conviction and that the trial court erred in admitting certain evidence at trial. Upon

review of the record and in light of applicable law and jurisprudence, we find no

merit to his assignments of error. Accordingly, we affirm his conviction.

PROCEDURAL BACKGROUND

On October 29, 2014, the defendant was charged by grand jury indictment

with two counts of aggravated incest of the juvenile victim, A.A.,2 between the

dates of January 1, 2011 and October 15, 2012. On December 8, 2014, the

defendant appeared for arraignment, in case number 14-02838, and pled not guilty

to the two counts in the indictment.

1 Effective June 12, 2014, La. Acts 2014, Nos. 177 and 602, repealed La. R.S. 14:78.1, “aggravated incest,” and amended and reenacted La. R.S. 14:89.1, “aggravated crime against nature,” to include the elements and penalties of the crime of aggravated incest. Thus, “aggravated incest” was redesignated “aggravated crimes against nature” under La. R.S. 14:89.1. “No change in the substantive proscriptions of Louisiana law were effected—only the placement of the conduct constituting the offense in the aggravated crime against nature offense—and the repeal of the offense of Aggravated Incest.” State v. Barbain, 15-0404, p. 2, n. 3 (La. App. 4 Cir. 11/4/15), 179 So.3d 770, 773 (citation omitted). 2 In this opinion, the initials of the victim, rather than the full name of the minor child, are used to protect and maintain the privacy of the minor child. See La. R.S. 46:1844(W)(1); Rule 5-2, Uniform Rules, Courts of Appeal.

1 On December 15, 2015, the defendant filed a motion in limine to exclude

from evidence written pornographic stories discovered on the defendant’s laptop

computer, seized pursuant to a search warrant for the defendant’s residence. The

following day, the State filed a response to the defendant’s motion to exclude,

arguing that the evidence was admissible pursuant to La. C.E. art. 412.2.3 That

same date, the trial court held a hearing on the defendant’s motion, but the trial

court deferred ruling on the motion until trial. Shortly thereafter, on December 21,

2015, the defendant filed a notice of a request for a bench trial.

On May 30, 2017, the defendant was indicted on an additional count of

aggravated incest of the juvenile victim, A.A., occurring between December 1,

2012 and August 1, 2013. Under case number 17-1835, the defendant appeared for

arraignment on June 12, 2017, and pled not guilty to the charge in the second

indictment.

The two cases, 14-2838 and 17-1835, were consolidated for the purposes of

trial. The bench trial took place over three days, February 21 and 22, 2018, and

March 9, 2018. On the last day of trial, the State sought to admit the written

pornographic material, which was the subject of the defendant’s prior motion in

limine. Over the defendant’s objection, the trial court admitted the evidence. At

3 La. C.E. art. 412.2 provides as follows:

A. When an accused is charged with a crime involving sexually assaultive behavior, or with acts that constitute a sex offense involving a victim who was under the age of seventeen at the time of the offense, evidence of the accused’s commission of another crime, wrong, or act involving sexually assaultive behavior or acts which indicate a lustful disposition toward children may be admissible and may be considered for its bearing on any matter to which it is relevant subject to the balancing test provided in Article 403. B. In a case in which the state intends to offer evidence under the provisions of this Article, the prosecution shall, upon request of the accused, provide a reasonable notice in advance of trial of the nature of any such evidence it intends to introduce at trial for such purposes. C. This Article shall not be construed to limit the admission or consideration of evidence under any other rule.

2 the conclusion of trial testimony and arguments, the trial court took the matter

under advisement.

On March 28, 2018, the trial court rendered its verdict. Based upon the

testimony and evidence presented at trial, the trial court found the defendant guilty

of all three counts of aggravated incest, as follows: in case number 14-2838,

(Count 1) aggravated incest by committing indecent behavior with a juvenile, in

violation of La. R.S. 14:78.1(B)(1); (Count 2) aggravated incest by lewd fondling

or touching, in violation of La. R.S. 14:78.1(B)(2); and in case number 17-1835,

(Count 1) aggravated incest by lewd fondling or touching, in violation of La. R.S.

14:78.1(B)(2).

On August 8, 2018, the defendant appeared for sentencing. Prior to

sentencing the defendant, the trial court noted that the victim in this case was a

juvenile under the age of thirteen years at the time of the offenses; and, pursuant to

the applicable statute, the sentence to be imposed would be not less than twenty-

five years, without benefit of parole, probation, or suspension of sentence, and not

more than ninety-nine years. The trial court then sentenced the defendant to the

mandatory minimum sentence of twenty-five years at hard labor without benefit of

parole, probation, or suspension of sentence, as to each count, to run concurrent.

The defendant now appeals his convictions. Before discussing the

defendant’s assignments of error on appeal, we review the facts and evidence

presented at trial.

STATEMENT OF FACTS

On October 19, 2012, the nine year-old victim, A.A., reported to her fourth

grade teacher, Erin Cosse, that she was being sexually abused by her stepfather, the

defendant. Ms. Cosse testified that A.A.’s school behavior had changed in the

3 preceding week and that she had asked A.A. if anything was wrong. At the end of

the class day, A.A. told Ms. Cosse she was ready to tell her what was wrong and

asked to speak with her in the hallway. A.A. then told Ms. Cosse that the

defendant was sexually abusing her. Upon receiving this information, Ms. Cosse

brought A.A. to the school nurse, Rebecca Amos.

Ms. Amos testified that Ms. Cosse brought A.A. to her office and stated only

that A.A. had something she needed to tell her. Ms. Amos asked A.A. what was

wrong, at which time A.A. reported that her stepfather, the defendant, was sexually

abusing her. Ms. Amos asked A.A. to explain what she meant by that; and A.A.

responded that the defendant showed her videos of men and women naked together

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State of Louisiana v. Joseph Peterson, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-louisiana-v-joseph-peterson-lactapp-2020.