State Of Louisiana v. Marcus Clayton

CourtLouisiana Court of Appeal
DecidedJanuary 15, 2025
Docket2024KA0080
StatusUnknown

This text of State Of Louisiana v. Marcus Clayton (State Of Louisiana v. Marcus Clayton) 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. Marcus Clayton, (La. Ct. App. 2025).

Opinion

STATE OF LOUISIANA

FIRST CIRCUIT

VERSUS

MARCUS CLAYTON

Judgment Rendered: JAN 15 2024

On Appeal from the 19' Judicial District Court Parish of East Baton Rouge, State of Louisiana Trial Court No. 21- 01142

The Honorable Louise Hines, Judge Presiding

Hillar C. Moore, III Attorneys for Appellee, District Attorney State of Louisiana Dylan C. Alge

Assistant District Attorney Baton Rouge, Louisiana

Jacob Longman Attorneys for Defendant -Appellant, Kathryn Jakuback Burke Marcus Clayton F. Richard Sprinkle Baton Rouge, Louisiana

Harry Daniels, III Prairieville, Louisiana

BEFORE: WOLFE MILLER AND GREENE Tj

5 p k, WOLFE, J.

The defendant, Marcus Clayton, was charged by bill of information with

nineteen counts of possession with the intent to distribute a Schedule II controlled

dangerous substance ( oxycodone) ( counts one through nineteen), in violation of

La. R.S. 40: 967( A) and 40: 964( A)( 1)( p); two counts of possession with the intent

to distribute a Schedule III controlled dangerous substance ( suboxone) ( counts

twenty and twenty- one), in violation of La. R.S. 40: 968( A) and 40: 964( D)(2)( a);

five counts of possession with the intent to distribute a Schedule IV controlled

dangerous substance ( alprazolam) ( counts twenty-two through twenty- six), in

violation of La. R.S. 40: 969( A) and 40: 964( B)( 2); and four counts of illegally

carrying a firearm while in possession of a controlled dangerous substance ( counts

twenty- seven through thirty), in violation of La. R.S. 14: 95( E).' Though initially

pleading not guilty, the defendant later pled guilty to the amended charges of

possession of oxycodone with an aggregate weight of two grams or more but less

than twenty- eight grams ( counts one and two), in violation of La. R.S.

40: 967( C)( 2). The State dismissed the remaining charges and, thereafter, the

defendant was sentenced to consecutive terms of five years at hard labor on each

count. The defendant filed a motion for reconsideration or modification of

sentence and a motion to withdraw guilty plea and set aside sentence, both of

which were denied. The defendant now appeals, designating two assignments of error. For the following reasons, we vacate and set aside the convictions and

sentences and remand the matter for further proceedings consistent with this

opinion.

We note the bill of information contains several citation omissions and errors. For counts twenty and twenty- one, the defendant was erroneously charged with violating La. R. S. 40: 964( D)( 2)( 1), and for counts twenty-two through twenty-six, the defendant was erroneously charged with violating La. R.S. 40: 964( B)( 1. 5). It is well- settled the statute in effect at the time of the commission of the offense controls. See State v. Sugasti, 2001- 3407 ( La. 6/ 21/ 02), 820 So. 2d 518, 520- 21. At the time of the commission of the offenses - September 22, 2020 - the correct citations for the respective charges were La. R.S. 40:964(D)( 2)( a) and 40:964(B)( 2). 2 FACTS

Because the defendant pled guilty, the facts were not developed at trial.

However, during the defendant' s plea colloquy, the State provided the following

factual basis for the charges:

Back in 2020, the Narcotics Division of the East Baton Rouge [ Parish] Sheriff' s Office was investigating the transfer and possession of oxycodone. They spoke with a confidential informant who stated she had gotten oxycodone from an individual named Marcus. She agreed to wear a hidden recording device. On that device, it showed an individual identified as Marcus Clayton possessing oxycodone. With those recordings, . . . the Narcotics Division ... applied for multiple warrants both at addresses known to Marcus Clayton and a car shop that he had. They executed those warrants at those locations. They found more oxycodone.

ASSIGNMENTS OF ERROR

In his first assignment of error, the defendant alleges he was denied effective

assistance of counsel when his attorney, who was suspended from practicing law at

the time of the plea, promised he would receive a probated sentence. In his second

assignment of error, he argues the trial court erred in denying his motion to

withdraw guilty plea, as his plea was based on counsel' s promise of a probated

sentence. As the issues are interrelated, we will address them together.

A guilty plea is a conviction and, therefore, should be afforded a great

measure of finality. State v. Emerson, 2023- 0120 ( La. App. 1st Cir. 9/ 15/ 23), 375 So. 3d 1027, 1029. As a general proposition, the validity of a guilty plea turns on

whether the defendant was informed of three fundamental constitutional rights—

his privilege against compulsory self-incrimination, his right to trial by jury, and his right to confront his accuser's— and whether, having been informed of those

rights, the defendant knowingly and voluntarily waived them. State v. Smith, 2014- 0578 ( La. App. 1st Cir. 11/ 7/ 14), 167 So. 3d 736, 738, writ denied, 2014-

3 2566 ( La. 10/ 2/ 15), 178 So. 3d 987. Here, the defendant argues his pleas were not

knowing or voluntary on account of counsel' s ineffective assistance.'

A defendant is entitled to effective assistance of counsel under the Sixth

Amendment to the United States Constitution and Article 1, § 13 of the Louisiana

Constitution of 1974. Under the standard for ineffective assistance of counsel set

forth in Strickland v. Washington, 466 U.S. 668, 104 S. Ct. 2052, 80 L.Ed.2d 674

1984), a conviction must be reversed if the defendant proves: ( 1) that counsel' s

performance fell below an objective standard of reasonableness under prevailing

professional norms; and ( 2) that counsel' s inadequate performance prejudiced the

defendant to the extent that the trial was rendered unfair and the verdict suspect.

See State v. McGee, 2018- 1052 ( La. 2/ 25/ 19), 264 So. 3d 445, 446 ( per curiam).

For claims like the defendant' s, that counsel' s ineffective assistance rendered a

guilty plea invalid, the Strickland analysis under the first deficiency prong

remains unchanged. Whereas, under the second prejudice prong, " the defendant

must show that there is a reasonable probability that, but for counsel' s errors, he

would not have pleaded guilty and would have insisted on going to trial." Hill v.

Lockhart, 474 U.S. 52, 58- 59, 106 S. Ct. 366, 370, 88 L.Ed.2d 203 ( 1985).

A valid guilty plea must be a voluntary choice by the defendant and not the

result of force or threats. La. Code Crim. P. art. 556. 1( B). Prior to accepting a

guilty plea, the court must personally inform the defendant of the nature of the

charge to which the plea is offered, any mandatory minimum penalty, and the

maximum possible penalty. La. Code Crim. P. art. 556. 1( A)( 1). When the record

Generally, an ineffective assistance of counsel claim is most appropriately addressed through an application for post -conviction relief filed in the trial court, where a full evidentiary hearing can be conducted, if necessary, rather than by direct appeal. State v. Anderson, 2023- 0271 ( La. App. 1st Cir. 11/ 3/ 23), 2023 WL 7270839, * 4 ( unpublished), writ denied, 2023- 01591 ( La.

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Related

Boykin v. Alabama
395 U.S. 238 (Supreme Court, 1969)
Strickland v. Washington
466 U.S. 668 (Supreme Court, 1984)
Hill v. Lockhart
474 U.S. 52 (Supreme Court, 1985)
State v. Taylor
887 So. 2d 589 (Louisiana Court of Appeal, 2004)
State v. Sugasti
820 So. 2d 518 (Supreme Court of Louisiana, 2002)
State v. Lewis
421 So. 2d 224 (Supreme Court of Louisiana, 1982)
State v. Green
468 So. 2d 1344 (Louisiana Court of Appeal, 1985)
State v. Galliano
396 So. 2d 1288 (Supreme Court of Louisiana, 1981)
State v. Smith
167 So. 3d 736 (Louisiana Court of Appeal, 2014)

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State Of Louisiana v. Marcus Clayton, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-louisiana-v-marcus-clayton-lactapp-2025.