State of Louisiana v. Quantell Derell Anders

CourtLouisiana Court of Appeal
DecidedSeptember 27, 2006
DocketKA-0006-0589
StatusUnknown

This text of State of Louisiana v. Quantell Derell Anders (State of Louisiana v. Quantell Derell Anders) 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. Quantell Derell Anders, (La. Ct. App. 2006).

Opinion

STATE OF LOUISIANA COURT OF APPEAL, THIRD CIRCUIT

06-589

STATE OF LOUISIANA

VERSUS

QUANTELL DERELL ANDERS

**********

APPEAL FROM THE NINTH JUDICIAL DISTRICT COURT PARISH OF RAPIDES, NO. 276283 HONORABLE DONALD THADDEUS JOHNSON, DISTRICT JUDGE

ULYSSES GENE THIBODEAUX CHIEF JUDGE

Court composed of Ulysses Gene Thibodeaux, Chief Judge, Jimmie C. Peters, and J. David Painter, Judges.

AFFIRMED AND REMANDED WITH INSTRUCTIONS.

James C. Downs District Attorney - Ninth Judicial District Court P. O. Drawer 1472 Alexandria, LA 71309 Telephone: (318) 473-6650 COUNSEL FOR: Plaintiff/Appellee - State of Louisiana

Annette Fuller Roach Louisiana Appellate Project P. O. Box 1747 Lake Charles, LA 70602-1747 Telephone: (337) 436-2900 COUNSEL FOR: Defendant/Appellant - Quantell Derell Anders Harold A. Van Dyke, III First Assistant District Attorney P. O. Box 1472 909 6th Street Alexandria, LA 71309 Telephone: (318) 473-6650 COUNSEL FOR: Plaintiff/Appellee - State of Louisiana THIBODEAUX, Chief Judge.

The Defendant, Quantell Derell Anders, appeals his jury conviction for

the lesser included offense of sexual battery in violation of La.R.S. 14:43.1. He was

charged with forcible rape. The Defendant complains about the propriety of denying

a motion in limine, the allowance of a special jury charge requested by the State, and

the alleged error of the trial court in ordering the jury to continue to deliberate and

return a verdict.

For the following reasons, we affirm.

LAW AND DISCUSSION

Motion in Limine

The Defendant contends the trial court erred when it denied his motion

in limine. The Defendant filed a motion in limine on February 14, 2006, seeking to

have the trial court determine the extent and nature of the testimony to be allowed

regarding D.H.’s attire at the time of the offense. Therein, the Defendant asserted

D.H. allowed him into her home between the hours of 1:00 and 2:00 a.m. while

dressed “only in underwear and wrapped in a blanket.”

At the hearing on the motion, defense counsel informed the trial court

that D.H. and the Defendant acknowledged, in their statements to police, that the

Defendant was admitted into D.H.’s home between 1:00 and 2:00 a.m. and D.H. had

gotten out of bed, was in her underwear, and had wrapped a blanket around herself.

Additionally, D.H. remained that way for approximately an hour, at which time the

alleged offense occurred. Defense counsel argued that the information regarding

D.H.’s attire should be available to the jury “to judge consent, simply because it’s the

hour and the location. This is not at a bar. This is her home under two o’clock in the

morning, and that’s the way she allows somebody to come into the -- to her home, and stays that way for at least an hour.” Defense counsel then insisted the Defendant’s

constitutional right to present a defense should preempt the exclusion of evidence

mandated by La.Code Evid. art. 412.1. The trial court then denied the motion, stating

it was the court’s intention to strictly construe Article 412.1. As a result, defense

counsel informed the court that he would proffer the recorded statements of D.H. and

the Defendant. However, the statements were not proffered and are not part of the

record in this matter.

Louisiana Code of Evidence Article 412.1 provides as follows:

When an accused is charged with the crime of aggravated rape, forcible rape, simple rape, sexual battery, or second degree sexual battery, the manner and style of the victim’s attire shall not be admissible as evidence that the victim encouraged or consented to the offense; however, items of clothing or parts thereof may be introduced in order to establish the presence or absence of the elements of the offense and the proof of its occurrence.

There is no jurisprudence interpreting this article.

The Defendant contends La.Code Evid. art. 412.1 was not designed to

cover situations similar to the present case; therefore, the trial court erred in strictly

construing the article and denying his right to present testimony concerning D.H.’s

lack of attire other than her underwear. The Defendant further contends D.H.’s lack

of attire would have supported his assertion that she consented to sexual intercourse

and, as he was not allowed to present testimony regarding her attire, he was deprived

of his constitutional right to due process and the right to confront his accuser. The

Defendant also asserts that, had the jury heard evidence of how D.H. was clothed, it

would have been in a better position to weigh the credibility of D.H. and himself.

The Defendant contends that, once D.H. realized there was no emergency, she had

ample opportunity to either end the conversation with him or excuse herself to dress

2 in more appropriate clothing, as the blanket D.H. used to cover herself cannot be

considered attire for purposes of Article 412.1.

The Defendant then discusses La.Code Evid. art. 404. He concedes that

it is not directly on point. He notes that Article 404 prohibits the introduction of

character evidence and other criminal acts, except in limited circumstances. The

Defendant then cites the following from the Official Comments to Article 404:

(b) Paragraph A codifies the general rule prevailing in Louisiana and throughout the country that, with certain exceptions, character evidence is inadmissible to prove that a person did or did not do a particular act on a particular occasion. Evidence falling within one of the exceptions listed in this Article must nevertheless pass the balancing test of Article 403. In some cases overriding constitutional principles may necessitate admission of evidence not falling within the categories listed in this Article. See U.S. Const.Amend. 6; La.Const. Art. 1, § 16 (1974). See State v. Ludwig, 423 So.2d 1073 (La.1982); State v. Vaughn, 431 So.2d 358 (La.1983). For example, in an appropriate case, constitutional principles may require the admission of evidence tending to show the character of a third person who[] the accused contends committed the offense.1

The Defendant asserts the legislature realized, when enacting Article 404, that the

constitutional rights of a defendant could outweigh the legislative intent. It,

therefore, recognized that a balancing test was necessary in deciding the admissibility

of evidence under Article 404. The Defendant then notes that the legislature did not

provide for a balancing test when enacting Article 412.1, which specifically prohibits

the introduction of evidence of a sexual assault victim’s attire to prove consent.

The Defendant asserts the legislature and the courts cannot protect the

victim of a sexual assault at the expense of a defendant’s right to present a defense.

In support of his argument, the Defendant cites State v. Vaughn, 431 So.2d 358

(La.1982), as follows:

1 We have not cited the exact quote found in appellate counsel’s brief, as it contains information not found in the Official Comments to La.Code Evid. art. 404.

3 Defendants were constitutionally entitled to offer relevant evidence in support of the defense of consent.3 They were also constitutionally entitled to impeach the credibility of their accuser with relevant evidence.4

....

. . . The evidence was certainly relevant to the defense theory.6 . . .

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State of Louisiana v. Quantell Derell Anders, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-louisiana-v-quantell-derell-anders-lactapp-2006.