State of Louisiana v. Marcel N. Dugar

CourtLouisiana Court of Appeal
DecidedNovember 27, 2024
DocketKA-0024-0190
StatusUnknown

This text of State of Louisiana v. Marcel N. Dugar (State of Louisiana v. Marcel N. Dugar) 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. Marcel N. Dugar, (La. Ct. App. 2024).

Opinion

STATE OF LOUISIANA COURT OF APPEAL, THIRD CIRCUIT

KA 24-190

STATE OF LOUISIANA

VERSUS

MARCEL N. DUGAR

**********

APPEAL FROM THE FOURTEENTH JUDICIAL DISTRICT COURT PARISH OF CALCASIEU, NO. 2439-21 HONORABLE CLAYTON DAVIS, DISTRICT JUDGE

LEDRICKA J. THIERRY JUDGE

Court composed of Gary J. Ortego, Ledricka J. Thierry, and Wilbur L. Stiles, Judges.

AFFIRMED AS AMENDED. Edward K. Bauman Louisiana Appellate Project P.O. Box 1641 Lake Charles, LA 70602 (337) 491-0570 COUNSEL FOR DEFENDANT/APPELLANT Marcel N. Dugar

Marcel N. Dugar Tensas Parish Detention Center 8606 Highway 65 Waterproof, LA 71375 (318) 749-5810 PRO SE DEFENDANT/APPELLANT Marcel N. Dugar

Steven C. Dwight District Attorney David S. Pipes Assistant District Attorney 901 Lakeshore Drive, Suite 800 Lake Charles, LA 70601 (337) 437-3400 COUNSEL FOR PLAINTIFF/APPELLEE State of Louisiana

2 THIERRY, Judge.

Defendant, Marcel N. Dugar, was convicted of unauthorized entry of an

inhabited dwelling, in violation of La.R.S. 14:62.3, and simple kidnapping, in

violation of La.R.S. 14:45. He was sentenced to six years for the unauthorized

entry conviction and ten years for the kidnapping, with the sentences to run

concurrently. Defendant appeals both the conviction and sentence. For the reasons

that follow, we affirm as amended.

FACTS AND PROCEDURAL HISTORY

On December 21, 2020, Defendant, took L.M.,1 the eight-month-old child of

Janera Brown, away from Brown’s residence without permission. Defendant was

neither the father nor the legal guardian of the child.

On January 20, 2021, the State, by bill of information, charged Defendant,

Marcel N. Dugar, with home invasion, a violation of La.R.S. 14:62.8, and

aggravated kidnapping of a child, a violation of La.R.S. 14:44.2. Defendant, on

February 22, 2021, pled not guilty.

On September 21, 2021, a jury unanimously found Defendant guilty of

unauthorized entry of an inhabited dwelling, a violation of La.R.S. 14:62.3, and of

aggravated kidnapping of a child.

However, on appeal this court found that Defendant had been denied his

right to self-representation and reversed Defendant’s convictions and sentences.

State v. Dugar, 22-461 (La.App. 3 Cir. 1/25/23), 354 So.3d 881, writ denied, 23-

193 (La. 9/6/23), 369 So.3d 1267.

1 Pursuant to La.R.S. 46:1844(W), the victim’s initials are used to protect his identity. On April 5, 2023, the State filed an amended bill of information, again

charging Defendant with aggravated kidnapping of a child. In place of home

invasion, however, Defendant was charged with unauthorized entry of an inhabited

dwelling.

Defendant’s second trial began on May 1, 2023. Defendant, with the

assistance of counsel, represented himself. On May 2, 2023, the jury found him

guilty of unauthorized entry of a dwelling and of simple kidnapping. Defendant

then filed a motion for new trial which the trial court denied on May 15, 2023.

On June 8, 2023, a habitual offender bill of information charging Defendant

as a second or subsequent offender was filed. The trial court did not specifically

find Defendant a habitual offender, but he was sentenced pursuant to La.R.S.

15:529.1.

On July 5, 2023, the trial court sentenced Defendant to six years for

unauthorized entry of an inhabited dwelling and ten years for simple kidnapping.

These sentences were imposed to run concurrently with each other but

consecutively to Defendant’s parole. The trial court denied Defendant’s motion to

reconsider sentence on July 28, 2023.

Defendant filed the instant appeal on April 16, 2024. There are two appellant

briefs on record. The first was filed by the Louisiana Appellate Project; the second

was filed by the Defendant in a pro se capacity. Together, Defendant asserts five

assignments of error.

ERRORS PATENT

In accordance with La.Code Crim.P. art. 920, this court reviews all appeals

for errors patent on the face of the record. After reviewing the record, we find an

2 error patent concerning Defendant’s habitual offender sentences and an error

patent concerning the advice for filing an application for post-conviction relief.

First, La.R.S. 15:529.1(G) required Defendant’s habitual offender sentences

to be imposed at hard labor. Although the court minutes indicate the sentences

were imposed to be served in the Louisiana Department of Corrections, the

transcript does not so indicate. Thus, the sentences are illegally lenient. See State v.

Perkins, 13-245 (La.App. 3 Cir. 11/6/13), 124 So.3d 605. Although the authority to

correct an illegally lenient sentence is granted and discretionary under La.Code

Crim.P. art. 882, the State contends that resentencing is required due to the trial

court’s failure to specify whether Defendant’s sentences were to be served with or

without hard labor. Accordingly, although we find the State’s claim that the trial

court erred in failing to specify with or without hard labor has no merit, we submit,

pursuant to La.Code Crim.P. art. 882, the sentences should be amended to reflect

they are to be served at hard labor. See State v. Matthew, 07-1326 (La.App. 3 Cir.

5/28/08), 983 So.2d 994, writ denied, 08-1664 (La. 4/24/09), 7 So.3d 1193.

Next, the record does not indicate that the trial court advised Defendant of

the prescriptive period for filing post-conviction relief at sentencing as required by

La.Code Crim.P. art. 930.8. Thus, we find that the trial court should inform

Defendant of the provisions of La.Code Crim.P. art. 930.8 by sending appropriate

written notice to Defendant within ten days of the rendition of this opinion and to

file written proof in the record that Defendant received the notice. See State v.

Viltz, 18-184, p. 12 (La.App. 3 Cir. 11/28/18), 261 So.3d 847; see also State v.

Roe, 05-116 (La.App. 3 Cir. 6/1/05), 903 So.2d 1265, writ denied, 05-1762 (La.

2/10/06), 924 So.2d 163.

3 ASSIGNMENTS OF ERROR

Defendant alleges five assignments of error on appeal. The first is set forth

by his counsel and the remaining four are alleged by Defendant in a pro se

capacity.

ASSIGNMENT OF ERROR:

1. When viewed in the light most favorable to the prosecution, the evidence introduced at trial was insufficient to convict Marcel Dugar of simple kidnapping beyond a reasonable doubt.

PRO SE ASSIGNMENTS OF ERROR:

1. Whether there was sufficient evidence to find Defendant guilty of simple kidnapping beyond a reasonable doubt.

2. Whether simple kidnapping is a responsive verdict to the charge of aggravated kidnapping.

3. Whether Defendant should have been permitted to present a ‘justification’ defense in his closing argument.

4. Whether Defendant’s sentence is unconstitutionally excessive.

ASSIGNMENT OF ERROR AND PRO SE ASSIGNMENT OF ERROR NO. 1:

Whether There Was Sufficient Evidence for the Jury to Find Defendant Guilty of Simple Kidnapping Beyond a Reasonable Doubt

In his first assignment of error, Defendant contends the jury did not have

sufficient evidence to find he had the specific intent to take Janera Brown’s child

“for an unlawful purpose.”

Relevant Law

The analysis for insufficient-evidence claims is well settled:

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. Watkins
532 So. 2d 1182 (Louisiana Court of Appeal, 1988)
State v. Barling
779 So. 2d 1035 (Louisiana Court of Appeal, 2001)
State v. Kennerson
695 So. 2d 1367 (Louisiana Court of Appeal, 1997)
State v. Davis
448 So. 2d 645 (Supreme Court of Louisiana, 1984)
State v. Richardson
425 So. 2d 1228 (Supreme Court of Louisiana, 1983)
State v. Telsee
425 So. 2d 1251 (Supreme Court of Louisiana, 1983)
State v. Cook
674 So. 2d 957 (Supreme Court of Louisiana, 1996)
State v. Smith
775 So. 2d 640 (Louisiana Court of Appeal, 2000)
State v. Roe
903 So. 2d 1265 (Louisiana Court of Appeal, 2005)
State v. Bowman
966 So. 2d 104 (Louisiana Court of Appeal, 2007)
State v. Harper
970 So. 2d 592 (Louisiana Court of Appeal, 2007)
State v. Sepulvado
367 So. 2d 762 (Supreme Court of Louisiana, 1979)
State v. Gill
441 So. 2d 1204 (Supreme Court of Louisiana, 1983)
State Ex Rel. Graffagnino v. King
436 So. 2d 559 (Supreme Court of Louisiana, 1983)
State v. Smith
846 So. 2d 786 (Louisiana Court of Appeal, 2003)
State v. Duncan
420 So. 2d 1105 (Supreme Court of Louisiana, 1982)
State v. Lisotta
726 So. 2d 57 (Louisiana Court of Appeal, 1998)
State v. Etienne
746 So. 2d 124 (Louisiana Court of Appeal, 1999)
State v. Moody
393 So. 2d 1212 (Supreme Court of Louisiana, 1981)

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State of Louisiana v. Marcel N. Dugar, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-louisiana-v-marcel-n-dugar-lactapp-2024.