State Of Louisiana v. Patrick James Kraemer

CourtLouisiana Court of Appeal
DecidedSeptember 27, 2019
Docket2019KA0470
StatusUnknown

This text of State Of Louisiana v. Patrick James Kraemer (State Of Louisiana v. Patrick James Kraemer) 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. Patrick James Kraemer, (La. Ct. App. 2019).

Opinion

STATE OF LOUISIANA

COURT OF APPEAL

FIRST CIRCUIT

2019 KA 0470

VERSUS

PATRICK JAMES KRAEMER V

Judgment Rendered: SEP 2 7 2019

On Appeal from the 22nd Judicial District Court In and for the Parish of St. Tammany State of Louisiana No. 597061- 1

Honorable Scott Gardner, Judge Presiding

Warren L. Montgomery Attorneys for Appellee, District Attorney State of Louisiana Matthew Caplan

Assistant District Attorney Covington, Louisiana

Bertha M. Hillman Attorney for Defendant/Appellant, Covington, Louisiana Patrick James Kraemer

BEFORE: HIGGINBOTHAM, PENZATO, AND LANIER, JJ.

a14 t aALo ( 74t- 0-41C c --

L LAt 5 . PENZATO, J.

The defendant, Patrick James Kraemer, was charged by bill of information

with three counts of theft of a firearm, violations of La. R.S. 14: 67. 15. He pled not

guilty. Following a jury trial, he was found guilty as charged on all counts. On

each count, he was sentenced to ten years at hard labor without benefit of parole,

probation, or suspension of sentence and " a single $ 1000[. 00] fine." Thereafter,

the State filed a habitual offender bill of information against the defendant.' The

defendant admitted to the allegations in the habitual offender bill. The court

adjudged him a second -felony habitual offender on count I, vacated the sentence

previously imposed, and resentenced him to twelve years at hard labor without

benefit of probation, parole, or suspension of sentence on count I. The court also

ordered that the sentences on all three counts be served concurrently. He now

appeals, contending: ( 1) the trial court erred in denying a request for a special jury

charge; and ( 2) the evidence was insufficient to support the convictions. For the

following reasons, we affirm the convictions, the habitual offender adjudication

and sentence on count I, amend the sentences on counts II and III, and affirm the

sentences on counts II and III as amended.

FACTS

On October 3, 2017, Carl Muir reported that someone had stolen three of his

firearms. Hilda Kraemer,2 the defendant' s grandmother, had stored the guns in her

home for Muir when he worked out-of-state. The defendant lived in Hilda' s home.

In 2016, he had taken four firearms, including one of the same firearms involved in

the instant offenses, and pawned them. In regard to the instant offenses, Hilda

testified Emily Sipos told her the defendant stole the guns, and she sold them to her

1 The predicate offense was set forth as the defendant' s February 13, 2017 conviction under 22nd Judicial District Court Docket No. 582263 for illegal possession of stolen firearms.

Z We will refer to Hilda Kraemer as " Hilda" to avoid confusion with the defendant.

2 drug dealer. Hilda indicated that after the 2016 incident, she told the defendant she

had returned the guns to Muir.

SUFFICIENCY OF THE EVIDENCE

In assignment of error number two, the defendant argues the evidence was

insufficient to support the convictions because Sipos was a drug addict and liar who

took the guns and pled guilty to their theft. On appeal, the defendant acknowledges

that he admitted taking Sipos to New Orleans to sell the guns in a recorded statement,

but he denied stealing the guns. Lastly, the defendant argues he was not guilty as a

principal to the theft of the guns because he " only participated in `transportation and

facilitation' after the taking." In cases such as this one, where the defendant raises

issues on appeal both as to the sufficiency of the evidence and as to one or more trial

errors, the reviewing court should preliminarily determine the sufficiency of the

evidence, before discussing the other issues raised on appeal. When the entirety of

the evidence, both admissible and inadmissible, is sufficient to support the

conviction, the accused is not entitled to an acquittal, and the reviewing court must

review the assignments of error to determine whether the accused is entitled to a new

trial. State a Hearold, 603 So.2d 731, 734 ( La. 1992); State a Smith, 2003- 0917 ( La.

App. 1st Cir. 12/ 31/ 03), 868 So. 2d 794, 798. Accordingly, we will first address the

defendant' s second assignment of error, which challenges the sufficiency of the

State' s evidence.

A conviction based on insufficient evidence cannot stand, as it violates due

process. See U.S. Const. amend. XIV; La. Const. art. I, § 2. In reviewing claims

challenging the sufficiency of the evidence, this court must consider " whether, after

viewing the evidence in the light most favorable to the prosecution, any rational trier

of fact could have found the essential elements of the crime beyond a reasonable

doubt." Jackson a Virginia, 443 U.S. 307, 319, 99 S. Ct. 2781, 2789, 61 L.Ed.2d 560

1979); see also La. C. Cr.P. art. 821( B); State a Mussall, 523 So. 2d 1305, 1308- 09

Q La. 1988). The Jackson standard, incorporated in Article 821, is an objective

standard for testing the overall evidence, both direct and circumstantial, for

reasonable doubt. State a Watts, 2014- 0429 ( La. App. 1st Cir. 11/ 21/ 14), 168 So. 3d

441, 444, writ denied, 2015- 0146 ( La. 11/ 20/ 15), 180 So.3d 315.

When a conviction is based on both direct and circumstantial evidence, the

reviewing court must resolve any conflict in the direct evidence by viewing that

evidence in the light most favorable to the prosecution. When analyzing

circumstantial evidence, La. R.S. 15: 438 provides that, in order to convict, the fact

finder must be satisfied that the overall evidence excludes every reasonable

hypothesis of innocence. The facts then established by the direct evidence and

inferred from the circumstances established by that evidence must be sufficient for a

rational trier of fact to conclude beyond a reasonable doubt that the defendant was

guilty of every essential element of the crime. Watts, 168 So. 3d at 444.

All persons concerned in the commission of a crime, whether present or

absent, and whether they directly commit the act constituting the offense, aid and

abet in its commission, or directly or indirectly counsel or procure another to commit

the crime, are principals. La. R.S. 14: 24. However, the defendant' s mere presence at

the scene is not enough to " concern" him in the crime. Only those persons who

knowingly participate in the planning or execution of a crime may be said to be

concerned" in its commission, thus making them liable as principals. A principal

may be connected only to those crimes for which he has the requisite mental state.

State a Neal, 2000- 0674 ( La. 6/ 29/ 01), 796 So. 2d 649, 659, cert. denied, 535 U.S.

940, 122 S. Ct. 1323, 152 L.Ed.2d 231 ( 2002). However, "[ i] t is sufficient

encouragement that the accomplice is standing by at the scene of the crime ready to

give some aid if needed, although in such a case it is necessary that the principal

actually be aware of the accomplice' s intention." State a Anderson, 97- 1301 ( La.

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Related

Jackson v. Virginia
443 U.S. 307 (Supreme Court, 1979)
State v. Smith
868 So. 2d 794 (Louisiana Court of Appeal, 2003)
State v. Mussall
523 So. 2d 1305 (Supreme Court of Louisiana, 1988)
State v. Bindom
410 So. 2d 749 (Supreme Court of Louisiana, 1982)
State v. Calloway
1 So. 3d 417 (Supreme Court of Louisiana, 2009)
State v. Turner
13 So. 3d 695 (Louisiana Court of Appeal, 2009)
State v. Neal
796 So. 2d 649 (Supreme Court of Louisiana, 2001)
State v. Anderson
707 So. 2d 1223 (Supreme Court of Louisiana, 1998)
State v. Cayton
721 So. 2d 542 (Louisiana Court of Appeal, 1998)
State v. Price
952 So. 2d 112 (Louisiana Court of Appeal, 2006)
State v. Hearold
603 So. 2d 731 (Supreme Court of Louisiana, 1992)
State v. Ordodi
946 So. 2d 654 (Supreme Court of Louisiana, 2006)
State of Louisiana v. Quint Mire
269 So. 3d 698 (Supreme Court of Louisiana, 2016)
State v. Thomas
112 So. 3d 875 (Louisiana Court of Appeal, 2012)
State v. Watts
168 So. 3d 441 (Louisiana Court of Appeal, 2014)
State v. Carter
210 So. 3d 306 (Louisiana Court of Appeal, 2016)
State v. Green
211 So. 3d 683 (Louisiana Court of Appeal, 2017)
Washington v. State, 2009-2105 (La. 8/18/10)
42 So. 3d 400 (Supreme Court of Louisiana, 2010)
State v. Lambert
93 So. 3d 771 (Louisiana Court of Appeal, 2012)

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