State of Louisiana v. Mary Henderson Trahan

CourtLouisiana Court of Appeal
DecidedNovember 2, 2016
DocketKW-0015-0848
StatusUnknown

This text of State of Louisiana v. Mary Henderson Trahan (State of Louisiana v. Mary Henderson Trahan) 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. Mary Henderson Trahan, (La. Ct. App. 2016).

Opinion

NOT DESIGNATED FOR PUBLICATION

STATE OF LOUISIANA

COURT OF APPEAL, THIRD CIRCUIT

15-848

VERSUS

MARY HENDERSON TRAHAN

************

APPEAL FROM THE FIFTEENTH JUDICIAL DISTRICT COURT PARISH OF LAFAYETTE, NO. CR 124728 HONORABLE EDWARD RUBIN, DISTRICT JUDGE

************ SYLVIA R. COOKS JUDGE ************

Court composed of Sylvia R. Cooks, Billy H. Ezell, and John E. Conery, Judges.

WRIT DENIED.

Keith A. Stutes District Attorney - 15th JDC Daniel M. Landry, III, ADA P.O. Box 3306 Lafayette, LA 70502 (337) 232-5170 COUNSEL FOR APPELLEE: State of Louisiana

John Clay LeJeune Attorney at Law P.O. Box 1919 Crowley, LA 70527 (337) 788-1505 COUNSEL FOR APPELLANT: Mary Henderson Trahan COOKS, Judge.

On August 18, 2010, Relator, Mary Henderson Trahan, was found guilty of

second degree murder. Relator was sentenced on August 26, 2010, to life

imprisonment without the benefit of probation, parole, or suspension of sentence.

Relator filed an appeal with this court. On July 6, 2011, this court vacated the

conviction and sentence and ordered the trial court to enter an acquittal.1 State v.

Trahan, 11-148 (La.App. 3 Cir. 7/6/11), 69 So.3d 1240. The State sought review,

and the Louisiana Supreme Court reversed this court’s decision and reinstated

Relator’s conviction and sentence and remanded to the trial court for execution of

the sentence. State v. Trahan, 11-1609 (La. 7/2/12), 97 So.3d 994.

On June 30, 2014, Relator timely filed an application for post-conviction

relief with the trial court. A hearing on the PCR was held on November 6, 2014.

Counsel presented argument, and the trial court ruled: “As I recall he [trial

counsel] did a good job. I’m going to deny the motion.” On December 8, 2014,

Relator filed a notice of appeal and designation of record with the trial court. On

December 10, 2014, the trial court granted Relator’s motion.

This court lodged the appeal record on May 18, 2015. On May 19, 2015,

this court issued a rule to show cause why this matter should not be dismissed, as

the judgment at issue was not an appealable judgment. La.Code Crim.P. art. 930.6.

On June 15, 2015, defense counsel filed a response to this court’s rule to show

cause acknowledging that the proper remedy would have been to file an

application invoking supervisory jurisdiction and asking this court to consider the

appeal as an application for writ of supervisory review.

Relator’s appeal was dismissed on August 5, 2015. However, she was

permitted to file a proper application for supervisory writs, in compliance with 1 Judge Gremillion dissented and found the evidence was sufficient to enter the responsive verdict of negligent homicide. Uniform Rules—Courts of Appeal, Rule 4, no later than thirty days from the date

of that decision. State v. Trahan, 15-452 (La.App. 3 Cir. 8/5/15) (unpublished

opinion).

On September 9, 2015, this court received Relator’s timely application for

supervisory review, wherein she alleged the following fourteen assignments of

error: 1) her conviction was based on insufficient evidence; 2) the presumption of

a motive violated Relator’s right to due process of law; 3) Relator’s right to due

process of law was violated by the court’s reliance on a statement by Relator that

was never introduced at trial; 4) the court’s emphasis on motive violated Relator’s

right to due process of law; 5) the court’s ruling that defense counsel’s opening

statement amounted to a stipulation of fact shifted the burden of proof and

precluded counsel from adjusting his defense; 6) the court’s finding that defense

counsel must set forth facts that he intended to prove at trial impermissibly shifted

the burden to Relator to prove her innocence; 7) the court erred in relieving the

State from its burden of proving each and every element of the crime charged

beyond a reasonable doubt; 8) the court’s ruling that the jury could consider facts

not in evidence—Relator’s statement to the police—violated her right to due

process of law; 9) the court’s ruling that the jury could rely on statements of

defense counsel as evidence violated Relator’s right to due process of law; 10) the

court erred in ruling that the jury could presuppose Relator was lying;

11) ineffective assistance of counsel for failure to challenge blood spatter

testimony; 12) ineffective assistance of counsel for failure to adequately cross-

examine witnesses; 13) ineffective assistance of counsel for failure to support the

defense theory; and 14) ineffective assistance of counsel for failure to introduce

any evidence attacking the incomplete prosecution. Relator also tangentially raised

several claims first raised but never addressed on appeal. On April 13, 2016, this matter was granted and placed on the docket for

consideration of the matter on the merits.2 Briefs were subsequently submitted by

Relator and the State.

Relator’s writ first assigns error with respect to trial counsel’s theory

presented during opening statements, which indicated that Relator was fearful of

the victim and that the shooting may have been accidental. Relator argues that her

attorney’s failure to adequately build and present the defense’s theory throughout

trial led the jury to convict her.

Relator also asserts that the supreme court’s decision stood for the

proposition that “the jury may rely on the argument of defense counsel, rather than

the evidence,” citing the following portion of the supreme court’s decision:

It clearly appears that most of the extra-record information provided by counsel came not from the state but from the defense when counsel outlined in his opening remarks the hypothesis of innocence, based on a statement jurors would never hear, that defendant slipped in her bathroom after disarming the victim and fired accidentally in the culminating event of an abusive relationship and a day-long argument. . . .

Jurors were therefore entitled at the close of the evidence to hold the defense accountable for its failure to introduce any evidence in support of the hypothesis of innocence proposed by defense counsel, apart from the coroner’s vague statement in response to questioning by the defense that he understood some sort of altercation had occurred earlier on the day of the shooting, a detail far more helpful to the state than the defense because it provided the only evidence of motive in the case.

Trahan, 97 So.3d at 998. Relator faults trial counsel for not eliciting testimony to

support or contradict the theory presented during opening statements and argues

the supreme court held that defense counsel’s failure to produce any evidence in

support of his theory was the basis for the conviction and life sentence.

Relator argues her attorney was ineffective for failing to object during the

State’s opening statement when it referred to the 911 call and argued Defendant

2 Judge Ezell dissented and would have denied the writ application on the merits. confessed during the call. The jury requested to review the 911 call during

deliberations, but that request was denied because the trial court found the call was

testimonial and not documentary in nature.

Relator next asserts trial counsel’s failure to present a complete defense

actually provided the only evidence to support the prosecution, asserting that the

911 tape and the opening and closing remarks, taken together, were sufficient to

convict.

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Related

Hudson v. Louisiana
450 U.S. 40 (Supreme Court, 1981)
Strickland v. Washington
466 U.S. 668 (Supreme Court, 1984)
State v. Bienemy
483 So. 2d 1105 (Louisiana Court of Appeal, 1986)
State v. Sias
861 So. 2d 829 (Louisiana Court of Appeal, 2003)
State v. TRUEHILL
38 So. 3d 1246 (Louisiana Court of Appeal, 2010)
State v. Collins
896 So. 2d 1265 (Louisiana Court of Appeal, 2005)
State v. Schexnaider
852 So. 2d 450 (Louisiana Court of Appeal, 2003)
State v. Duplichan
945 So. 2d 170 (Louisiana Court of Appeal, 2006)
State v. Brooks
505 So. 2d 714 (Supreme Court of Louisiana, 1987)
State v. Trahan
69 So. 3d 1240 (Louisiana Court of Appeal, 2011)
State v. State, 2008-1448 (La. 3/27/09)
5 So. 3d 138 (Supreme Court of Louisiana, 2009)
State v. Sarpy
52 So. 3d 1032 (Louisiana Court of Appeal, 2010)
State v. Trahan
97 So. 3d 994 (District Court of Appeal of Florida, 2012)
State v. Knight
829 So. 2d 1160 (Louisiana Court of Appeal, 2002)

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