State of Louisiana v. Nathaniel Mitchell, III

CourtLouisiana Court of Appeal
DecidedApril 11, 2024
DocketKA-0023-0415
StatusUnknown

This text of State of Louisiana v. Nathaniel Mitchell, III (State of Louisiana v. Nathaniel Mitchell, III) 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. Nathaniel Mitchell, III, (La. Ct. App. 2024).

Opinion

NOT DESIGNATED FOR PUBLICATION

STATE OF LOUISIANA COURT OF APPEAL, THIRD CIRCUIT

23-415

STATE OF LOUISIANA

VERSUS

NATHANIEL MITCHELL, III

**********

APPEAL FROM THE FOURTEENTH JUDICIAL DISTRICT COURT PARISH OF CALCASIEU, NO. 19635-19 HONORABLE G. MICHAEL CANADAY, DISTRICT JUDGE

SHARON DARVILLE WILSON JUDGE

Court composed of Elizabeth A. Pickett, Candyce G. Perret, and Sharon Darville Wilson, Judges.

AFFIRMED. Annette Roach LOUISIANA APPELLATE PROJECT P.O. Box 6547 Lake Charles, Louisiana 70606 (337) 436-2900 COUNSEL FOR DEFENDANT/APPELLANT Nathaniel Mitchell, III

Hon. Stephen C. Dwight, District Attorney David S. Pipes, Assistant District Attorney CALCASIEU PARISH DISTRICT ATTORNEY’S OFFICE 901 Lakeshore Drive, Suite 800 Lake Charles, Louisiana 70601 (337) 437-3400 COUNSEL FOR APPELLEE State of Louisiana WILSON, Judge.

A jury found Defendant, Nathaniel Mitchell, III, guilty of second-

degree murder, in violation of La.R.S. 14:30.1. The trial court sentenced Mr.

Mitchell to serve life in prison without benefit of probation, parole, or suspension of

sentence. Mr. Mitchell now seeks review of his conviction. For the following

reasons, we affirm the conviction and sentence, and Mr. Mitchell’s ineffective

assistance of counsel claim is relegated to post-conviction relief.

I.

ISSUES

We must decide:

(1) whether the trial court erred in allowing the State to introduce various recordings into evidence when the recordings were not properly authenticated;

(2) whether the trial court erred in allowing the State to place into evidence a gun cleaning kit found during a search of the home of Mr. Mitchell’s ex-wife; and

(3) whether counsel rendered assistance below that guaranteed by the Sixth Amendment, resulting in prejudice to Mr. Mitchell.

II.

FACTS AND PROCEDURAL HISTORY

Late afternoon on July 17, 2019, several teenagers found the burned

body of a male at the dead end of D. Williams Road in DeQuincy, Louisiana. The

teenagers notified law enforcement, and several days passed before police were able

to identify the male from a DNA hit. The body was that of Zacchaeus Hakim Burton.

On September 5, 2019, Mr. Mitchell was charged alongside George Anthony Buck

with the second-degree murder of Mr. Burton, in violation of La.R.S. 14:30.1. On

May 25, 2022, an amended indictment was filed, adding a charge against George Buck for obstruction of justice, in violation of La.R.S. 14:130.1. On May 31, 2022,

Mr. Buck entered into a plea deal with the State in exchange for testimony against

Mr. Mitchell.

Trial began on September 27, 2022. On October 3, 2022, a jury found

Mr. Mitchell guilty of second-degree murder, specifically finding that he killed Mr.

Burton with a specific intent to kill or inflict great bodily harm. On November 7,

2022, Mr. Mitchell filed a motion for new trial contending his conviction was

contrary to law and evidence. On November 22, 2022, a hearing was held on the

motion, and it was denied by the trial court. On November 23, 2022, in accordance

with La.R.S. 14:30.1(B), Mr. Mitchell was sentenced to life in prison without benefit

of probation, parole, or suspension of sentence.

On December 6, 2022, Mr. Mitchell filed a motion for reconsideration

of sentence alleging that his life sentence was excessive and cruel and unusual

punishment. The motion was denied the same day without reasons. On September

6, 2023, the trial court held a resentencing hearing, at which time it specified that

Mr. Mitchell’s life sentence was to be served at hard labor and further clarified that

any possible diminution of sentence would be at the discretion of the Department of

Corrections. Mr. Mitchell now appeals.

III.

LAW AND DISCUSSION

ERRORS PATENT

In accordance with La.Code Crim.P. art. 920, all appeals are reviewed

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

are no errors patent.

VIDEO AUTHENTICATION

2 In his first assignment of error, Mr. Mitchell contends that the trial court

erred in allowing the State to introduce various recordings into evidence when the

recordings were not properly authenticated. A trial court’s ruling on the

admissibility of evidence is reviewed for an abuse of discretion. State v. Cosey, 97-

2020 (La. 11/28/00), 779 So.2d 675. Mr. Mitchell contends that the surveillance

videos were not properly authenticated because the State did not establish that the

various pieces of equipment were properly maintained and that the recordings’ time

stamps were accurate. Mr. Mitchell maintains that proper authentication required

that the person whose equipment recorded the video be called as a witness to

authenticate the evidence. We disagree.

Louisiana Code of Evidence Article 901 states, in pertinent part:

A. General provision. The requirement of authentication or identification as a condition precedent to admissibility is satisfied by evidence sufficient to support a finding that the matter in question is what its proponent claims.

B. Illustrations. By way of illustration only, and not by way of limitation, the following are examples of authentication or identification conforming with the requirements of this Article:

The article then goes on to list ten non-exclusive means of authenticating evidence

including “(B)(1) Testimony of witness with knowledge. Testimony that a matter

is what it is claimed to be[;]” “(B)(4) Distinctive characteristics and the like.

Appearance, contents, substance, internal patterns, or other distinctive

characteristics, taken in conjunction with circumstances[;]” and “(B)(9) Process or

system. Evidence describing a process or system used to produce a result and

showing that the process or system produces an accurate result.”

In the present case, various detectives testified to retrieving various

surveillance recordings and provided firsthand accounts of the recovery of the

3 videos. Each officer described what was captured on the surveillance, how it was

captured and how they determined the video’s accuracy. As explicitly stated in

La.Code Evid. art. 901(B)(1), testimony of a witness with knowledge that the

evidence is what it is purported to be is sufficient to authenticate the evidence.

To support his argument, Mr. Mitchell relies heavily on the fourth

circuit’s decision in State in Interest of J.H., 22-324 (La.App. 4 Cir. 8/9/22), 369

So.3d 827. In J.H., the court held that the testimony from a detective regarding his

familiarity with the area, location of cameras, and previous experience was

insufficient to authenticate surveillance videos. Specifically, the court stated:

Here, the State offered no testimony from a person who maintained the surveillance video system that recorded the video, to describe the process or system by which the video was created and to attest to the accuracy of the system. However, as argued by the State, Det. Bidichandani testified that he was familiar with the neighborhood of the Melpomene Housing Development, where the incident occurred; he knew to contact Mr. Pollard, the security director, about video surveillance; he retrieved the video footage from Mr. Pollard; and, from “previous experience collecting video footage from this area”, he knew “that their camera systems and layout is accurate.”

We find Det. Bidichandani’s testimony fails to lay the proper foundation for authentication of this video evidence. Det.

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Related

Strickland v. Washington
466 U.S. 668 (Supreme Court, 1984)
Yates v. Evatt
500 U.S. 391 (Supreme Court, 1991)
Sullivan v. Louisiana
508 U.S. 275 (Supreme Court, 1993)
State v. Cosey
779 So. 2d 675 (Supreme Court of Louisiana, 2000)
State v. Ratcliff
416 So. 2d 528 (Supreme Court of Louisiana, 1982)
State v. Peart
621 So. 2d 780 (Supreme Court of Louisiana, 1993)
State v. Chesson
856 So. 2d 166 (Louisiana Court of Appeal, 2003)
State v. Rice
222 So. 3d 32 (Supreme Court of Louisiana, 2017)

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State of Louisiana v. Nathaniel Mitchell, III, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-louisiana-v-nathaniel-mitchell-iii-lactapp-2024.