State of Louisiana v. MacHell Rodgers

CourtLouisiana Court of Appeal
DecidedApril 14, 2021
DocketKW-0021-0190
StatusUnknown

This text of State of Louisiana v. MacHell Rodgers (State of Louisiana v. MacHell Rodgers) 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. MacHell Rodgers, (La. Ct. App. 2021).

Opinion

STATE OF LOUISIANA

COURT OF APPEAL, THIRD CIRCUIT

21-190

VERSUS

MACHELL RODGERS

**********

ON APPLICATION FOR SUPERVISORY WRIT FROM THE TWELFTH JUDICIAL DISTRICT COURT PARISH OF AVOYELLES, NO. 211,754 HONORABLE WILLIAM J. BENNETT, DISTRICT JUDGE

VAN H. KYZAR JUDGE

Court composed of John D. Saunders, Van H. Kyzar, and Charles G. Fitzgerald, Judges.

WRIT DENIED.

Charles A. Riddle, III District Attorney - 12th Judicial District Anthony Francis Salario Assistant District Attorney P. O. Box 1200 Marksville, LA 71351 (318) 253-6587 Counsel for Plaintiff - Respondent: State of Louisiana

Chad P. Guillot Attorney at Law P. O. Drawer 158 Marksville, LA 71351 (318) 253-6656 Counsel for Defendant - Applicant Machell Rodgers KYZAR, Judge.

Defendant, Machell Rodgers, filed the instant pre-trial application for a writ

of review from the trial court’s denial of a motion for a special jury instruction to

1 be given at his scheduled May 10, 2021 trial. For the reasons herein, we deny the

writ application.

FACTS AND PROCEDURAL BACKGROUND

Defendant was charged on January 23, 2019, with theft over $25,000, a

violation of La.R.S. 14:67. The bill of information alleges the offense occurred

“on or about January 16, 2018.” On September 2, 2020, Defendant filed a “Motion

to Allow Special Jury Instruction Regarding Nonunanimous Verdict” in the trial

court alleging the United States Supreme Court’s ruling in Ramos v. Louisiana,

590 U.S. ___, 140 S.Ct. 1390 (2020), does not affect Louisiana’s law allowing a

ten-to-two verdict to acquit. He sought a special jury instruction at trial saying at

least ten jurors must concur to find him not guilty, but all twelve jurors must

concur to find him guilty. The trial court held the Ramos Court “threw out

[A]rticle 782 of the Code of Criminal Procedure” and denied the motion at a

hearing on November 17, 2020. Defendant now seeks review of the denial of his

motion.

DISCUSSION

Louisiana Code of Criminal Procedure Article 802(1) requires that the trial

court in criminal cases charge the jury “[a]s to the law applicable to the case[.]” ______________________ 1 Christopher K. Gaines, Jr., filed an identical motion for the same jury charge in his criminal case under docket numbers 209,985 and 209,986 before the same trial court as did Paul Fox in docket number 207,523. Identical writs have been filed in connection with the denial of their motions. Those writs are before this court in docket numbers 21-189 and 21-191, respectively. Louisiana Code of Criminal Procedure Article 807 gives to the state and the

defendant “the right before argument to submit to the court special written charges

for the jury” but specifically provides that “[a] requested special charge shall be

given by the court if it does not require qualification, limitation, or explanation,

and if it is wholly correct and pertinent. It need not be given if it is included in the

general charge or in another special charge to be given.” The language “shall”

within the statute connotes that it is a mandatory requirement of the trial court, but

only when the requested charge is “wholly correct” and not in need of further

“qualification” or “explanation.” Id.

Defendant seeks a special jury instruction at trial that would inform the jury

of twelve people that at least ten jurors must concur to find him not guilty, but all

twelve jurors must concur to find him guilty. He contends the United States

Supreme Court’s decision in Ramos, 140 S.Ct. 1390, requires a unanimous verdict

to convict but not to acquit a defendant. He cites no authority for his position other

than Ramos. We conclude that this is not a “wholly correct” statement of the law,

and the trial court did not err in denying Defendant’s motion for the charge.

The offense in the instant case was committed on or about January 16, 2018.

Louisiana Constitution Article l, § 17(A), as amended by 2018 La. Acts No. 493,

effective January l, 2019, reads, in pertinent part:

A case for an offense committed prior to January l, 2019, in which the punishment is necessarily confinement at hard labor shall be tried before a jury of twelve persons, ten of whom must concur to render a verdict. A case for an offense committed on or after January l, 2019, in which the punishment is necessarily confinement at hard labor shall be tried before a jury of twelve persons, all of whom must concur to render a verdict. Likewise, La.Code Crim.P. art. 782(A), as amended by the same act, states in

pertinent part:

2 A case in which punishment may be capital shall be tried by a jury of twelve jurors, all of whom must concur to render a verdict. A case for an offense committed prior to January l, 2019, in which punishment is necessarily confinement at hard labor shall be tried by a jury composed of twelve jurors, ten of whom must concur to render a verdict. A case for an offense committed on or after January l, 2019 in which the punishment is necessarily confinement at hard labor shall be tried before a jury of twelve persons, all of whom must concur to render a verdict.

For offenses committed on or after January l, 2019, a jury must, based on the

plain language of the Constitution and Article 782(A), unanimously concur in any

verdict, not solely in its guilty verdict. Thus, a jury in those cases must

unanimously reach a verdict to acquit as well. That the instant offense occurred

prior to the effective date of these provisions requires us to look to Ramos, 140

S.Ct. 1390, and other jurisprudence for guidance.

Ramos refers to a defendant’s “conviction” and a jury’s “verdict” and

concludes a guilty verdict must be unanimous to obtain a defendant’s conviction.

However, the Supreme Court thoroughly discusses the history of the unanimous

verdict requirement as referencing any verdict, not just a guilty one. A

nonunanimous jury verdict is an illegal and invalid verdict as per the Constitution.

The text and structure of the Constitution clearly suggest that the term “trial by an impartial jury” carried with it some meaning about the content and requirements of a jury trial.

One of these requirements was unanimity. Wherever we might look to determine what the term “trial by an impartial jury trial” meant at the time of the Sixth Amendment’s adoption—whether it’s the common law, state practices in the founding era, or opinions and treatises written soon afterward—the answer is unmistakable. A jury must reach a unanimous verdict in order to convict.

The requirement of juror unanimity emerged in 14th century England and was soon accepted as a vital right protected by the common law. As Blackstone explained, no person could be found guilty of a serious crime unless “the truth of every accusation . . . should . . . be confirmed by the unanimous suffrage of twelve of his equals and neighbors, indifferently chosen, and superior to all suspicion.” A “ ‘verdict, taken from eleven, was no verdict’ ” at all. 3 Id. at 1395 (footnotes omitted).

The Ramos opinion, authored by Justice Gorsuch, states, “We took this case

to decide whether the Sixth Amendment right to a jury trial—as incorporated

against the States by way of the Fourteenth Amendment—requires a unanimous

verdict to convict a defendant of a serious offense.” Id. at 1394 (emphasis added).

The opinion further addresses unanimous verdicts only in terms of convictions in

stating, “[a] jury must reach a unanimous verdict in order to convict[,]” and, “[s]o

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Related

State v. Goodley
423 So. 2d 648 (Supreme Court of Louisiana, 1982)
State v. Goodley
398 So. 2d 1068 (Supreme Court of Louisiana, 1981)
Ramos v. Louisiana
140 S. Ct. 1390 (Supreme Court, 2020)
Edwards v. Vannoy
140 S. Ct. 2737 (Supreme Court, 2020)

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State of Louisiana v. MacHell Rodgers, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-louisiana-v-machell-rodgers-lactapp-2021.