State of Louisiana v. Koby Dillon

CourtLouisiana Court of Appeal
DecidedSeptember 9, 2025
Docket2024-KA-0370
StatusPublished

This text of State of Louisiana v. Koby Dillon (State of Louisiana v. Koby Dillon) 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. Koby Dillon, (La. Ct. App. 2025).

Opinion

STATE OF LOUISIANA * NO. 2024-KA-0370

VERSUS * COURT OF APPEAL KOBY DILLON * FOURTH CIRCUIT * STATE OF LOUISIANA *******

APPEAL FROM 25TH JDC, PARISH OF PLAQUEMINES NO. 22-2359, DIVISION “B” Honorable Michael D. Clement, ****** Judge Sandra Cabrina Jenkins ****** (Court composed of Judge Sandra Cabrina Jenkins, Judge Nakisha Ervin-Knott, Judge Monique G. Morial)

Roger Williams Jordan, Jr. LAW OFFICE OF ROGER W. JORDAN, JR. 336 Lafayette Street, Suite 301 New Orleans, LA 70130

COUNSEL FOR DEFENDANT/APPELLANT

Charles Ballay District Attorney, Parish of Plaquemines Jason Napoli Assistant District Attorney, Parish of Plaquemines 333 F. Edward Hebert Boulevard, Building 201 Belle Chasse, LA 70037

COUNSEL FOR STATE/APPELLEE

CONVICTIONS AFFIRMED; SENTENCES AFFIRMED IN PART; VACATED IN PART; AND REMANDED SEPTEMBER 9, 2025 SCJ NEK MGM Defendant, Koby Dillon (“Dillon”), appeals his convictions and sentences on

Count 2, La. R.S. 40:966.A (1) & B (2)(a); Count 4, La. R.S. 14:95.E and Count 5,

La. R.S. 14:95.1. For the reasons that follow, we affirm all convictions and the

sentences in Counts 2 and 4. The sentence in Count 5 is vacated and set aside and

remanded to district court to impose the statutory fine pursuant to La. R.S. 14:95.1.

PROCEDURAL AND FACTUAL HISTORY

Dillon was charged by bill of information with possession with intent to

distribute Schedule I controlled dangerous substance (“CDS”) less than 2.5 lbs.,

(La. R.S. 40:966(A) & B(2)(a)); illegal use/possession/control of weapons-crime of

violence/CDS (La. R.S. 14:95(E)); and possession of or carrying a concealed

weapon by convicted felon (La. R.S. 14:95.1). Dillon entered pleas of not guilty to

all counts and the matter proceeded to trial on December 11, 2023. 1

1 Dillon was also charged with one count each of operating a vehicle with an obstructed windshield or window view (Count 1) and possession of drug paraphernalia (first offense) (Count 3), violations of La. R.S. 32:361.1 and 40:1025, respectively. The jury trial did not encompass these charges as they constitute misdemeanor offenses. The State dismissed both counts on February 28, 2024, following Dillon’s convictions of the remaining felony charges.

1 The State’s first witness was Detective Anthony Dugas (“Det. Dugas”),

assigned to the division of Drug Interdiction and Criminal Enforcement (“DICE”).

Det. Dugas was on patrol for traffic violations when he observed a 2020 Nissan

Altima with heavily tinted windows. Det. Dugas initiated a traffic stop and

subsequent thereto, Dillon rolled down his windows for officer safety. Det. Dugas

smelled the strong odor of marijuana emanating from the open windows and

conducted a search based on the smell.2 His search yielded a loaded, forty-five

caliber Glock handgun in the front center console, two large bags of loose

vegetable matter, a digital weight scale, one box of Great Value Ziplock sandwich

bags, as well as packets of seeds resembling marijuana seeds. Upon reviewing

Dillon’s driver’s license and determining the car was registered to him, Det. Dugas

placed Dillon under arrest and initiated a “criminal history check.” The check

revealed that Dillon had previous convictions for intimidation of a witness and

illegal possession of a firearm with a CDS.

The State introduced into evidence the items retrieved from the search, the

crime lab report that identified the vegetable matter seized as marijuana, and the

certified conviction penitentiary packet (“pen-pack”) of Dillon’s prior convictions.

In its case in chief, the defense called Ray’delle Jones (“Mr. Jones”), a

friend of Dillon. He testified that he owned the gun found in the search of Dillon’s

vehicle. On the day of the arrest, he claimed that he inadvertently left the gun in

Dillon’s car after Dillon had given him a ride home.

2 Det. Dugas contacted Detective David McLean (“Det. McLean”) to come to the scene as a

“cover” officer for officer safety. Det. McLean arrived on the scene, but did not participate in the search.

2 By unanimous verdict, Dillon was found guilty as charged on all three

counts. The defense filed a motion to reconsider sentence on December 18, 2023,

and thereafter, filed motions for a new trial and a judgment notwithstanding the

verdict on January 4, 2024. The district court denied the motions for a new trial

and judgment notwithstanding the verdicts on January 24, 2024.

At the sentencing hearing held on February 28, 2024, the district court

imposed the following sentences: five years imprisonment at hard labor for

possession of marijuana with the intent to distribute; twenty years imprisonment at

hard labor without the benefit of parole, probation, or suspension of sentence for

possession of a firearm while in possession of a CDS; and ten years imprisonment

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

possession of a firearm by a felon, with all sentences to run concurrently. The

district court orally denied Dillon’s December 18, 2023 motion to reconsider

sentence and granted Dillon’s timely motion for appeal.

ERRORS PATENT

A review of the record for errors patent reveals a sentencing error based on

the district court’s failure to impose the mandatory fine required for Dillon’s

conviction of possession of a firearm by a felon. Louisiana Revised Statute

14:95.1 provides that the offender shall be “imprisoned at hard labor for not less

than five nor more than twenty years without the benefit of probation, parole, or

suspension of sentence and be fined not less than one thousand dollars nor more

than five thousand dollars.” Here, the district court sentenced Dillon to serve ten

years at hard labor without benefit of probation, parole, or suspension of sentence,

but did not impose the mandatory fine. Accordingly, Dillon’s sentence for

3 possession of a firearm by a felon is vacated. The matter is remanded for re-

sentencing to comply with La. R.S. 14:95.1(B)(1).

ASSIGNMENTS OF ERROR

Dillon raises the following assignments of error:

1. The district court erred by failing to grant a mistrial when the State was allowed to introduce a non-enumerated felony— intimidation of a witness (La. R.S. 14:129.1)—as a predicate offense for felon in possession of a firearm (La. R.S. 14:95.1).

2. The district court erred in allowing the introduction of other crimes evidence at trial.

3. The testimony at trial was insufficient to convict for felon in possession of a firearm as the State failed to prove Dillon was in fact a convicted felon.

4. The testimony at trial was insufficient to show the substance seized was marijuana, a necessary element to convict for the offenses of possession with the intent to distribute marijuana and illegal possession of a weapon while in possession of a CDS.

5. The sentence imposed for possession of a firearm with a CDS was unconstitutionally excessive and the district court failed to comply with the sentencing guidelines of La. C.Cr.P. art. 894.1.

DISCUSSION

“[I]n accordance with the well-settled jurisprudence that ‘[w]hen issues are

raised on appeal as to the sufficiency of the evidence and as to one or more trial

errors, the reviewing court should first determine the sufficiency of the evidence.’”

State v. Miner, 2014–0939, p. 5 (La. App. 4 Cir. 3/11/15), 163 So.3d 132, 135

(quoting State v. Hearold, 603 So.2d 731, 734 (La. 1992).

Sufficiency of Evidence Claims

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Jackson v. Virginia
443 U.S. 307 (Supreme Court, 1979)
State v. Payton
810 So. 2d 1127 (Supreme Court of Louisiana, 2002)
State v. Hearold
603 So. 2d 731 (Supreme Court of Louisiana, 1992)
State v. Hayes
108 So. 3d 360 (Louisiana Court of Appeal, 2013)
State v. Oliphant
113 So. 3d 165 (Supreme Court of Louisiana, 2013)
State v. Miner
163 So. 3d 132 (Louisiana Court of Appeal, 2015)
State v. Turner
259 So. 3d 1089 (Louisiana Court of Appeal, 2018)

Cite This Page — Counsel Stack

Bluebook (online)
State of Louisiana v. Koby Dillon, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-louisiana-v-koby-dillon-lactapp-2025.