State of Louisiana v. Marcus Jackson

CourtLouisiana Court of Appeal
DecidedFebruary 28, 2024
Docket55,427-KW
StatusPublished

This text of State of Louisiana v. Marcus Jackson (State of Louisiana v. Marcus Jackson) 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 Jackson, (La. Ct. App. 2024).

Opinion

Judgment rendered February 28, 2024. Application for rehearing may be filed within the delay allowed by Art. 2166, La. C. Cr. P.

No. 55,427-KW COURT OF APPEAL SECOND CIRCUIT STATE OF LOUISIANA

*****

STATE OF LOUISIANA Respondent

versus

MARCUS JACKSON Applicant

On Application for Writs from the First Judicial District Court for the Parish of Caddo, Louisiana Trial Court No. 383,732

Honorable Erin Leigh Waddell Garrett, Judge

KENNETH J. BECK, PLC Counsel for Applicant By: Kenneth J. Beck

JAMES E. STEWART, SR. Counsel for Respondent District Attorney

ROSS STEWART OWEN Assistant District Attorney

Before THOMPSON, ROBINSON, and MARCOTTE, JJ. THOMPSON, J.

Marcus Jackson, the purported roommate of a parolee, was arrested

when drugs were found during a residence check of the parolee by a parole

officer. After observing drugs in the common area of the residence, a

warrantless search of the entire home followed, during which firearms were

discovered. Possession of firearms in addition to drugs is prohibited.

Jackson, who was not on parole, was charged with possession with

intent to distribute the drugs and illegal carrying of weapons while in

possession of a controlled dangerous substance. Jackson filed a motion to

suppress the evidence resulting from the warrantless search of the residence,

arguing that he maintained his rights to privacy in his own home, despite the

parolee’s diminished expectation of privacy. The trial court denied the

motion to suppress. For the following reasons, we affirm the denial of the

motion to suppress as it relates to the drugs discovered but reverse in relation

to firearms found in other areas of the home from the warrantless search,

finding no exigent circumstances existed to support such a search.

FACTS

Kelvin Hughes (“Hughes”) was released from incarceration and was

on parole under the supervision of Officer Sharie Cone (“Officer Cone”)

with the Louisiana Office of Probation and Parole. One requirement for

parolees is they maintain current residential addresses on file with their

parole officer. On May 25, 2021, Officer Cone went to the residence on Red

Bud Lane in Shreveport, Louisiana, provided by Hughes as his, in order to

make contact with him as a required condition of his parole. Hughes had

previously provided this address to the Office of Probation and Parole as the

place where he resided. The individual asserting ownership of the home is Marcus Jackson (“Jackson”), who is Hughes’ cousin. Jackson was not on

probation or parole at the time giving rise to this matter. Events occurring

during the residence check of Hughes at the residence by Officer Cone

resulted in a spontaneous search of Jackson’s entire home, which culminated

in Jackson’s arrest and his ultimately being charged by bill of information

with the following two counts:

(1) Possession with intent to distribute schedule I CDS (Marijuana) (less than 2.5 pounds) in violation of La. R.S. 40:966(A)(1) & (B)(2)(a).

(2) Illegal carrying of weapons while in possession of CDS, in violation of La. R.S. 14:95(E).

The spontaneous search was made without a warrant, and Jackson

subsequently moved to suppress the evidence obtained from the search in a

motion dated January 18, 2022. Jackson contended that Hughes’ diminished

expectation of privacy as a parolee did not diminish Jackson’s right to

privacy and the protections against warrantless searches of his home under

the Fourth Amendment of the U.S. Constitution and the La. Const. art. I, § 5.

Following an evidentiary hearing on May 30, 2023, where testimony

regarding the search was adduced, evidence submitted, and oral argument

made, the court denied the motion to suppress. The transcript of the hearing

details the establishment of the facts which follow.

On May 25, 2021, Officer Cone attempted to contact her parolee,

Hughes, at the address he supplied after he was released on parole – being

the residence at 3425 Red Bud Lane in Shreveport. The residence was

subsequently asserted to be owned by his cousin, Jackson. Officer Cone

testified that she previously attempted to visit Hughes at this address, but no

one was home. When she arrived at the house on this visit, Hughes opened

2 the door, and she stepped inside the house into the living room. Officer

Cone testified that she immediately saw on the coffee table two heat-sealed

packages of what is referred to by those familiar with drug use or in law

enforcement as “candy,” which she explained is a concoction of cereal

mixed with marijuana. According to her testimony, Officer Cone

immediately recognized the familiar-looking packages as contraband based

on her 31 years of experience on the job. She further testified that the use of

the heat-seal packaging indicated the intent to distribute the contraband, as

opposed to it being intended for personal use.

Officer Cone testified that when she recognized the packages as

marijuana candy, she read Hughes his Miranda rights and placed him under

arrest for violating the terms of his parole. She did not state whether she

handcuffed Hughes at that time. Officer Cone testified she asked Hughes if

there were other people in the house at the time; Hughes said that there was

one other person in the house – his cousin, Jackson. Hughes also told

Officer Cone that the marijuana candy belonged to Jackson.

Officer Cone testified that Jackson then entered the living room from

his bedroom wearing a bathrobe. As Jackson walked into the room, Hughes

said to him, “They found your candy.” Officer Cone testified that Jackson

responded, “Okay, so.” She testified she construed Jackson’s response to be

an admission that he owned the marijuana candy. Officer Cone then read

Jackson his Miranda rights, but did not specify whether she handcuffed

Jackson at that time. Officer Cone then asked Jackson if there “were there

any weapons in the residence?” Officer Cone said that Jackson responded

affirmatively, stating that he “had plenty.”

3 Officer Cone called for assistance to come in the house and do a

“violation search.” She did not ask Jackson for his consent to search any

areas of the house. The record shows that on the date of his arrest, Jackson

did not have any prior convictions, he was not on parole under her

supervision, and he had a permit for his guns. Officer Cone could not recall

if Jackson told her to stop searching his house. She testified that she did not

believe she needed Jackson’s consent to search the house:

We have – when someone is on parole and they live at a residence, we have all the common areas and their bedroom. And once you find any illegal substance in the common areas, it gives you the house.

The other officers came into the house and conducted a search of the

house. They found a total of 86.673 grams (slightly over 3 ounces) of

marijuana in the home. It is unclear from the record if this included the

marijuana candy found in the common area. Officer Cone said that the lab

never determined how much marijuana was in the marijuana candy, but she

concluded, based on her experience as a parole officer, that there was

enough to surpass the 14-gram requirement for making it a felony to possess

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State of Louisiana v. Marcus Jackson, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-louisiana-v-marcus-jackson-lactapp-2024.