State of Louisiana v. Kyvonte Latrell Eaglin

CourtLouisiana Court of Appeal
DecidedJuly 3, 2019
DocketKA-0017-0657
StatusUnknown

This text of State of Louisiana v. Kyvonte Latrell Eaglin (State of Louisiana v. Kyvonte Latrell Eaglin) 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. Kyvonte Latrell Eaglin, (La. Ct. App. 2019).

Opinion

STATE OF LOUISIANA COURT OF APPEAL, THIRD CIRCUIT

17-657

STATE OF LOUISIANA

VERSUS

KYVONTE LATRELL EAGLIN

**********

APPEAL FROM THE THIRTY-FIRST JUDICIAL DISTRICT COURT PARISH OF JEFFERSON DAVIS, NO. CR-716-15 HONORABLE CRAIG STEVE GUNNELL, DISTRICT JUDGE

ELIZABETH A. PICKETT JUDGE

ON REMAND FROM THE SUPREME COURT

Court composed of Sylvia R. Cooks, Elizabeth A. Pickett, and Phyllis M. Keaty, Judges.

CONVICTION VACATED AND REMANDED.

Alfred F. Boustany, II Boustany Law Firm P. O. Box 4626 Lafayette, LA 70502 (337) 261-0225 COUNSEL FOR DEFENDANT-APPELLANT: Kyvonte Latrell Eaglin Michael C. Cassidy District Attorney - 31st JDC Bennett R. LaPoint Assistant District Attorney P. O. Box 1388 Jennings, LA 70546 (337) 824-1893 COUNSEL FOR APPELLEE: State of Louisiana PICKETT, Judge.

FACTS

The defendant, Kyvonte Latrell Eaglin, attended a party at the American

Legion Hall in Jennings on August 8, 2015. An altercation broke out, and a group

moved outside. The defendant went to his vehicle and retrieved a gun. Shots from

one or more firearms were fired, and the victim was killed.

The defendant was convicted of manslaughter on November 18, 2016. The

trial court sentenced the defendant to twenty years at hard labor on January 30,

2017. This court affirmed his conviction and sentence. State v. Eaglin, 17-657

(La.App. 3 Cir. 3/28/18), 239 So.3d 1001, writ granted in part, 18-822 (La.

3/18/19), 265 So.3d 761 (per curiam).

One of the issues on appeal addressed the introduction of an inflammatory

photograph into evidence. This court held the photograph was in fact erroneously

introduced, but we found the error to be harmless. The Louisiana Supreme Court

granted the defendant’s writ application in part and remanded the matter, finding

this court “applied the wrong standard in determining whether the error was

harmless.” Eaglin, 18-822 at 1. The supreme court instructed this court to

reevaluate the error according to the standard set out in Chapman v. California,

386 U.S. 18, 87 S.Ct. 824 (1967).

DISCUSSION

At trial, the state introduced, as evidence of the defendant’s bad character, a

copy of a Facebook photograph of the defendant, who was approximately thirteen

years old at the time. The photograph falsely portrayed the defendant as a masked

armed robber holding a dangerous pistol to the back of a child’s head, as though

ready to shoot the child. The trial court itself described the photograph as

“inflammatory.” Later in the trial, the defendant’s sixteen-year-old cousin, Latavius Stewart, testified the photograph was taken approximately four years

earlier. Mr. Stewart was the boy standing against the wall while the defendant held

a BB gun against his head. Another cousin took the photo. Mr. Stewart said they

were “[j]ust having fun with it. We were being silly. Just taking pictures.”

This court found:

This photograph, Exhibit S-2, provided no useful purpose at trial. Chief D’Albor’s testimony did not show he relied on it at the scene to identify the defendant. Even if he had, it would still add nothing to help the jury reach a verdict. The photograph depicted nothing related to the crime for which the defendant was on trial. It did, however, present a disturbing image to the jury that portrayed the defendant as one who held a gun to a young boy’s head. Only later in the trial did the jury hear testimony explaining the photograph, which in itself did not cast the defendant in a particularly good light.

Eaglin, 239 So.3d at 1020. Thus, this court found the photograph to be “totally

irrelevant,” “highly prejudicial,” and without probative value, and it found the trial

court erred in admitting it into evidence. Id. at 1027. However, this court

reviewed the testimony of numerous witnesses, including the defendant’s own

testimony, and found “[t]here was consistent testimony regarding the fight that

preceded the shooting that was sufficient to convict the defendant of

manslaughter.” Id.

The Louisiana Supreme Court granted the defendant’s writ application in

part and remanded the matter, finding this court “applied the wrong standard.”

Eaglin, 18-822 at 2. The supreme court instructed this court “to determine whether

the state has proved beyond a reasonable doubt that the error complained of did not

contribute to the verdict obtained” in accordance with Chapman, 386 U.S. 18. Id.

Chapman standard

In Chapman, 386 U.S. 18, the state’s counsel made repeated references to

the defendants’ failure to testify during his closing argument to the jury, a practice

which California’s state constitution allowed at the time. After the trial, but before 2 the appeal reached the California Supreme Court, the U.S. Supreme Court found

the state constitutional provision invalid in Griffin v. State of California, 380 U.S.

609, 85 S.Ct. 1229 (1965). Nevertheless, the California Supreme Court affirmed

the Chapman defendants’ convictions, admitting the defendants had been denied a

federal constitutional right but finding the error harmless.

The Court explained:

The federal rule emphasizes “substantial rights” as do most others. The California constitutional rule emphasizes “a miscarriage of justice,” but the California courts have neutralized this to some extent by emphasis, and perhaps overemphasis, upon the court’s view of “overwhelming evidence.” We prefer the approach of this Court in deciding what was harmless error in our recent case of Fahy v. State of Connecticut, 375 U.S. 85, 84 S.Ct. 229, 11 L.Ed.2d 171. There we said: “The question is whether there is a reasonable possibility that the evidence complained of might have contributed to the conviction.” Id., at 86-87, 84 S.Ct. at 230 . . . . [Fahy] emphasizes an intention not to treat as harmless those constitutional errors that “affect substantial rights” of a party. An error in admitting plainly relevant evidence which possibly influenced the jury adversely to a litigant cannot, under Fahy, be conceived of as harmless. Certainly error, constitutional error, in illegally admitting highly prejudicial evidence or comments, casts on someone other than the person prejudiced by it a burden to show that it was harmless. It is for that reason that the original common-law harmless-error rule put the burden on the beneficiary of the error either to prove that there was no injury or to suffer a reversal of his erroneously obtained judgment. There is little, if any, difference between our statement in Fahy v. State of Connecticut about “whether there is a reasonable possibility that the evidence complained of might have contributed to the conviction” and requiring the beneficiary of a constitutional error to prove beyond a reasonable doubt that the error complained of did not contribute to the verdict obtained. We, therefore, do no more than adhere to the meaning of our Fahy case when we hold, as we now do, that before a federal constitutional error can be held harmless, the court must be able to declare a belief that it was harmless beyond a reasonable doubt.

Chapman, 386 U.S. at 23-24 (footnotes omitted).

The Court refined the Chapman rationale in Sullivan v. Louisiana, 508 U.S.

275, 113 S.Ct. 2078 (1993):

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Related

Fahy v. Connecticut
375 U.S. 85 (Supreme Court, 1963)
Griffin v. California
380 U.S. 609 (Supreme Court, 1965)
Chapman v. California
386 U.S. 18 (Supreme Court, 1967)
Rose v. Clark
478 U.S. 570 (Supreme Court, 1986)
Pope v. Illinois
481 U.S. 497 (Supreme Court, 1987)
Yates v. Evatt
500 U.S. 391 (Supreme Court, 1991)
Sullivan v. Louisiana
508 U.S. 275 (Supreme Court, 1993)
State v. Gibson
391 So. 2d 421 (Supreme Court of Louisiana, 1980)
State v. Johnson
664 So. 2d 94 (Supreme Court of Louisiana, 1995)
State v. Allen
913 So. 2d 788 (Supreme Court of Louisiana, 2005)
State v. Welcome
458 So. 2d 1235 (Supreme Court of Louisiana, 1984)
State v. Small
100 So. 3d 797 (Supreme Court of Louisiana, 2012)
State v. Magee
103 So. 3d 285 (Supreme Court of Louisiana, 2012)
Griffin v. California
380 U.S. 609 (Supreme Court, 1965)
State v. Eaglin
239 So. 3d 1001 (Louisiana Court of Appeal, 2018)
Thomas v. Maryland
470 U.S. 1088 (Supreme Court, 1985)

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State of Louisiana v. Kyvonte Latrell Eaglin, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-louisiana-v-kyvonte-latrell-eaglin-lactapp-2019.