State of Louisiana v. Nytilex Jones

Louisiana Court of Appeal·Decided August 5, 2020·No. 2019-KA-0440·Published

Opinion

STATE OF LOUISIANA * NO. 2019-KA-0440 VERSUS * COURT OF APPEAL NYTILEX JONES * FOURTH CIRCUIT

* STATE OF LOUISIANA

*******

APPEAL FROM

CRIMINAL DISTRICT COURT ORLEANS PARISH NO. 517-806, SECTION “K”

Honorable Arthur Hunter, Judge ******

Judge Joy Cossich Lobrano ******

(Court composed of Judge Roland L. Belsome, Judge Daniel L. Dysart, Judge Joy Cossich Lobrano)

Dysart, J., Dissents with Reasons

Leon Cannizzaro District Attorney Donna Andrieu Irena Zajickova DISTRICT ATTORNEY’S OFFICE ORLEANS PARISH 619 S. White Street New Orleans, LA 70119

COUNSEL FOR STATE/APPELLEE

Sherry Watters LOUISIANA APPELLATE PROJECT

P. O. Box 58769 New Orleans, LA 70158

Nytilex Jones #431888 Louisiana State Penitentiary Angola, LA 70712

Barksdale Hortenstine, Jr. ORLEANS PUBLIC DEFENDERS 2601 Tulane Avenue, 7th Floor New Orleans, LA 70119

COUNSEL FOR DEFENDANT/APPELLANT

CONVICTION AND SENTENCE VACATED;

REMANDED.

AUGUST 5, 2020

JCL, RLB The defendant, Nytilex Jones (“Defendant”), has appealed his conviction of second-degree murder and the mandatory sentence of life imprisonment at hard labor without the benefit of parole, probation, or suspension of sentence. After reviewing the record and applicable law, and for the following reasons, we vacate Defendant’s conviction and sentence and remand to the district court for a new trial.

PROCEDURAL HISTORY Defendant was charged with the July 27, 2013 second-degree murder of Samuel Kelly (“Victim”), a violation of La. R.S. 14:30.1. Defendant appeared for arraignment and entered a plea of not guilty. Defendant filed a motion to suppress evidence, statement, and identification the same day. After Defendant fired and obtained new counsel on numerous occasions, the State requested a mental competency evaluation and hearing. At the hearing on June 18, 2015, Defendant was represented by counsel from the New Orleans Office of Public Defenders (“OPD”). Because Defendant had been uncooperative during the evaluation, the court ordered another competency evaluation. At the second competency hearing

on August 13, 2015, during which Defendant was represented, the district court accepted the sanity commission’s recommendation and found Defendant competent to proceed to trial. On April 25, 2016, Defendant filed a pro se motion for a change of venue.

The district court subsequently denied Defendant’s motions for a change of venue, as well as previously filed motions to suppress evidence, identification, and statement. On September 26, 2016, Defendant filed a motion to recuse the district judge and the case was transferred from Section “C” to Section “K.” On May 3, 2017, Defendant filed a motion to exclude the video surveillance evidence. Following a hearing to determine authenticity and reliability, the motion was denied on September 29, 2017.

On November 21, 2017, Defendant moved for another mental competency evaluation and hearing. On November 28, 2017, defense counsel filed a motion to withdraw after Defendant again refused to accept assistance from appointed counsel. Defense counsel also filed motions for a psychiatric exam and to present basis for competency hearing. The district court granted the motion to withdraw and entered a finding on the record that defendant had voluntarily waived his right to assistance of counsel. The court then proceeded with the third hearing on the renewed competency motion at which Defendant was unrepresented. Defendant’s privately retained expert testified and recommended that another sanity

commission be appointed.1 The district court accepted the expert’s recommendation and ordered another competency evaluation. The district court held a competency hearing on December 19, 2017, and again found Defendant competent to proceed to trial. Defendant was unrepresented at this hearing.

Defendant proceeded to trial on June 5, 2018, pro se, but the district court declared a mistrial following opening statements during which Defendant demanded an attorney and agreed to accept the assistance of appointed counsel. On September 18, 2018, the morning of Defendant’s second trial, the court denied a renewed motion for a competency evaluation and began jury selection.2 Following a three-day trial during which Defendant was represented by counsel, the jury returned a unanimous verdict of guilty as charged. On October 9, 2018, Defendant filed motions for a new trial, post-verdict judgment of acquittal, arrest of judgment, and downward departure from the mandatory sentence, all of which were denied.

On October 11, 2018, the district court sentenced Defendant to the mandatory sentence of life imprisonment at hard labor without the benefit of parole, probation, or suspension of sentence over Defendant’s objection.

ERRORS PATENT A review of the record reveals no errors patent.

1 Dr. Sarah DeLand believed Defendant suffered from paranoid delusions that would affect his ability to assist his attorney, specifically, that the surveillance video was reconstructed and the entire criminal justice system was rigged against him. 2 Defense counsel unsuccessfully moved for reconsideration of the competency issue at every subsequent proceeding, bench conferences or discussions in chambers.

ASSIGNMENTS OF ERROR Defendant has assigned the six errors for our review. However, finding that the district court erred in allowing Defendant to represent himself during his final competency hearing, we pretermit discussion of the remaining assignments.

DISCUSSION Defendant contends that reversal of his conviction is required because he was denied counsel at his final competency hearing at which the court erroneously found him competent to proceed to trial.

The State responds that the district court had already found Defendant competent to proceed to trial following two competency hearings at which Defendant was represented by appointed counsel, therefore, the failure to have counsel at any subsequent competency hearing would be harmless error.

Defendant was afforded four competency hearings.3 The first, requested by the State, was held on June 18, 2015, at which Defendant was represented by OPD. Defendant was examined by Drs. Richard Richoux and Raphael Salcedo. Dr. Richoux testified that he could not complete the examination because Defendant was deliberately uncooperative. Dr. Richoux recommended that Defendant be remanded to a mental facility where he could be continuously observed to provide a more thorough evaluation.4

3 The first two hearings occurred while Defendant’s case was pending in Section “C” and the second two were conducted after the case was transferred to Section “K.” 4 Dr. Richoux also testified that Defendant stated he diagnosed himself as a paranoid schizophrenic, although he neither had been professionally diagnosed nor sought treatment for the condition (or any other mental condition). Dr. Salcedo concurred with Dr. Richoux’s assessment and recommendation.

The court rejected the recommendation.5 Defendant then questioned the authenticity of the video surveillance footage the State had provided in discovery and moved for its suppression. The court explained that his concerns could not be addressed until his competency was determined. Defendant insisted he was competent and submitted to the court a written pro se motion to suppress the footage. The court ordered a second mental evaluation and competency hearing.

On July 9, 2015, Defendant appeared for his second competency hearing without counsel. The court continued the hearing until he obtained new counsel.

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