State of Louisiana v. Kenneth J. Session

Louisiana Court of Appeal·Decided December 14, 2021·No. 2021-KA-0118·Published

Opinion

STATE OF LOUISIANA * NO. 2021-KA-0118

VERSUS * COURT OF APPEAL KENNETH J. SESSION * FOURTH CIRCUIT * STATE OF LOUISIANA *******

APPEAL FROM CRIMINAL DISTRICT COURT ORLEANS PARISH NO. 531-099, SECTION “DIVISION D” Judge Kimya M Holmes, ****** Judge Tiffany Gautier Chase ******

(Court composed of Judge Roland L. Belsome, Judge Daniel L. Dysart, Judge Tiffany Gautier Chase)

BELSOME, J., CONCURS WITH REASONS

Meghan Harwell Bitoun LOUISIANA APPELLATE PROJECT P.O. Box 4252 New Orleans, LA 70178--4252

COUNSEL FOR DEFENDANT/APPELLANT

Jason Rogers Williams DISTRICT ATTORNEY ORLEANS PARISH 619 S. White Street New Orleans, LA 70119

G. Benjamin Cohen Chief of Appeals, DISTRICT ATTORNEY 619 S. White Street New Orleans, LA 70119 David B. LeBlanc ASSISTANT DISTRICT ATTORNEY Appeals Division 619 S. White Street New Orleans, LA 70119

COUNSEL FOR APPELLEE, THE STATE OF LOUISIANA

AFFIRMED DECEMBER 14, 2021 TGC 1 DLD This is a criminal appeal. The defendant, Kenneth Session (hereinafter

“defendant”), seeks review of his conviction and sentence for sexual battery of a

victim under the age of thirteen. For the reasons that follow, we affirm.

PROCEDURAL HISTORY

On October 31, 2016, the State of Louisiana (hereinafter “the State”) filed a

bill of information charging defendant with molestation of a juvenile under the age

of thirteen, a violation of La. R.S. 14:81.2, and sexual battery of a victim under the

age of thirteen, a violation of La. R.S. 14:43.1(C)(2). At arraignment, defendant

pled not guilty to both counts. The case proceeded to trial on November 26, 2018,

but ended with a hung jury. The State chose to try defendant again, on only the

count of sexual battery of a victim under the age of thirteen.

Defendant was found guilty by a unanimous jury following his second trial.

On February 5, 2020, defendant was sentenced to fifty years imprisonment at hard

labor with credit for time served. The court ordered the defendant to serve thirty

years without the benefit of probation, parole, or suspension of sentence. On that

1 same date, the trial court denied defendant’s motion to reconsider sentence and

granted his motion for appeal.

STATEMENT OF THE FACTS

Defendant was tried and convicted for the sexual battery of C.R., his niece. 1

C.R., aged eighteen at the time of trial but eight years old when the abuse occurred,

described the incidents during which defendant abused her in detail at trial. She

disclosed the abuse to a friend, who told C.R.’s mother. C.R. also testified that she

had initially denied the allegations when asked about them by her mother and

grandmother.

C.R.’s cousin (“witness 2”), twenty-three years old at the time of trial,

testified pursuant to La. C.E. art 412.2 that defendant had raped her when she was

seventeen, after he discovered her with a boy against “house rules.”

Another relative (“witness 3”), also provided evidence of defendant’s lustful

disposition, describing two incidents. During the first incident, defendant forcibly

removed her bedcovers when she was spending the night with witness 2. On the

second, defendant raped her when she was twelve years old and babysitting

defendant’s children among others. Witness 3 reported the incident when she was

sixteen years old and the offense was prosecuted in Jefferson Parish. Witness 3’s

boyfriend also testified, confirming that she had reported the rape to him about a

year after it occurred.

A friend of C.R.’s (“witness 4”) corroborated her testimony. Witness 4

testified that she and C.R. discussed the allegations made by witness 3, which had

1 In accordance with La. R.S. 46:1844(W)(1)(a), to keep confidential the identities of the persons who were minors at the time of the offenses, initials have been used in place of their names. 2 been made public by that time, and that C.R. then tearfully told her that defendant

had molested her too. Witness 4 informed C.R.’s mother, who contacted police.

Dr. Anne Troy, qualified as an expert in the field of child sexual abuse,

interviewed C.R. Nothing during the interview suggested to the expert that C.R.

had been untruthful when she provided her account of abuse.

Defendant’s wife testified on his behalf. She admitted that witness 3 had

accused defendant of molesting her but maintained that she later retracted those

allegations. She also claimed that all the State’s fact witnesses had lied about her

husband’s conduct. She denied drinking with defendant before her night shift

working at a Bridge City correctional facility. However, her testimony was

impeached by rebuttal testimony from her sister, suggesting that defendant would

be left alone with witness 3 at night, when his wife went to work.

ERRORS PATENT

A review of the record reveals no errors patent.

DISCUSSION

Evidentiary Rulings

Assignment of Error No. 1: The Admission of Witness 2’s Testimony

In his first assignment of error, defendant avers that the trial court erred

when it admitted other crimes evidence whose probative value was outweighed by

its prejudicial effect, specifically witness 2’s testimony that defendant raped her

when she was seventeen. Witness 2 did not testify during defendant’s first trial

and the State filed a notice of intent to introduce her testimony as evidence of

similar crimes pursuant to La. C.E. art. 412.2. After a hearing, the trial court

determined that the probative value of witness 2’s testimony outweighed its

3 prejudicial effect.2 We review the trial court’s ruling under an abuse of discretion

standard. State v. Wright, 2011-0141, pp. 10-11 (La. 12/6/11), 79 So.3d 309, 316.

Defendant argues that the probative value of the evidence is outweighed by

the possibility of prejudice to him because the incident involving C.R. differs from

that involving witness 2. Defendant asserts that while C.R. was eight years old

when he inappropriately touched her, witness 2 was seventeen years old when her

alleged rape occurred. Defendant cites to State v. Parker, 42,311, p. 13-14 (La.

App. 2 Cir. 8/15/07), 963 So.2d 497, 507, wherein the Second Circuit determined

that evidence of sexual misconduct with adults was inadmissible in connection

with a charge of sexual misconduct with a minor. As in Parker, defendant

maintains that witness 2’s testimony should have been found inadmissible given

her age when she was raped. Defendant contends that another distinction between

the two incidents is that while the incident with C.R. was premeditated, the

incident with witness 2 was “an isolated instance of opportunity.” Defendant also

questions the reliability of witness 2’s testimony regarding her rape, as she did not

report the alleged offense until six years after it transpired.

The governing statutory provision regarding the admission of “prior bad

acts” evidence is La. C.E. art. 412.2(A), which provides:

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.

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