State Of Louisiana v. Rickey J. Lafont, Jr.

CourtLouisiana Court of Appeal
DecidedSeptember 15, 2023
Docket2023KA0086
StatusUnknown

This text of State Of Louisiana v. Rickey J. Lafont, Jr. (State Of Louisiana v. Rickey J. Lafont, Jr.) 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. Rickey J. Lafont, Jr., (La. Ct. App. 2023).

Opinion

STATE OF LOUISIANA

COURT OF APPEAL

FIRST CIRCUIT

NO. 2023 KA 0086

VERSUS 00 RICKEY J. LAFONT, JR.

Judgment Rendered: SEP 15 2023

Appealed from the 17th Judicial District Court In and for the Parish of Lafourche State of Louisiana Docket No. 599618

The Honorable Marla M. Abel, Judge Presiding

Kristine M. Russell Counsel for Appellee, District Attorney State of Louisiana Jason L. Chatagnier Assistant District Attorney Thibodaux, Louisiana

Barry S. Ranshi Counsel for Defendant/Appellant, John J. Mason Rickey J. Lafont, Jr. Kenner, Louisiana

BEFORE: McCLENDON, HESTER, AND MILLER, JJ. MILLER, J.

The defendant, Rickey J. Lafont, Jr., was charged by amended bill of

information with indecent behavior with a juvenile (count I), a violation of La. R. S.

14: 81( A)( 1)( H)(2); and sexual battery ( count II), a violation of La. R. S.

14: 43. 1( A)(2) & ( C)( 2).' He pled not guilty on both counts. Following a jury trial,

he was found guilty on both counts by unanimous verdicts. On count I, the

defendant was sentenced to twenty- five years at hard labor, two years without

benefit of probation, parole, or suspension of sentence. On count II, he was

sentenced to a concurrent term of forty years at hard labor, twenty- five years without

benefit of parole, probation, or suspension of sentence. The defendant now appeals

designating four assignments of error. For the following reasons, we affirm the

convictions and sentences.

FACTS

In July of 2020, S. M.,2 the nine-year-old victim, confided in her mother, A.M.,

that the defendant touched her between her legs. The defendant was A.M.' s live-in

boyfriend at that time. S. M. subsequently gave a statement to the Child Advocacy

Center regarding those allegations. In that statement, S. M. recounted that the

defendant began touching her when she was seven or eight years old. According to

S. M., the first incident occurred when S. M. and the defendant were lying on the

3 couch, covered by a blanket and watching anime. S. M. stated that the defendant

Count lZ of the bill of information ( erroneously identified as " Count I") set forth the essential facts corresponding with La. R.S. 14: 43. 1( C)( 2), but cited La. R. S. 14: 43. 1( 0)( 3). This error, however, is harmless because the defendant neither alleges nor proves he was misled to his prejudice. See La. C. Cr.P. arts. 464 & 921.

2W reference the victim and her mother herein only by their initials. See La. R.S. 46: 1844( W).

3" Anime" is defined by Merriam -Webster Dictionary as " a style of animation originating in Japan that is characterized by stark colorful graphics depicting vibrant characters in action - filled plots often with fantastic or futuristic themes. Merriam -Webster Online Dictionary, https:// merriain- wenster.cortttdictionat- rfanirne ( last visited August 22, 2023).

2 began to rub her private parts,4 and continued to do so after she told him to stop. She

further stated that the rubbing continued to occur, both over her clothes and under her

shorts and underwear. S.M. recalled that these incidents usually took place when

everyone else in the house was sleeping, and often while the defendant watched

anime or movies. The incidents allegedly occurred at the defendant' s residence in

Galliano. S. M., who was age eleven at the time of trial, testified at trial. Her trial

testimony was consistent with her statement given to the Child Advocacy Center.

The defendant testified at trial. He denied having sexual tendencies toward

children, denied being sexually aroused by children, denied touching S. M.' s vagina,

and denied rubbing her vagina under her clothes.

MOTION IN LIMINE

In his first assignment of error, the defendant contends the trial court erred in

denying his motion in limine seeking to exclude evidence of a 2019 conviction for

indecent behavior with a juvenile and in failing to enforce its limiting instruction to

the jury. He asks this court to analogize La. C.E. art. 412.2 to La. C.E. art. 404(B)( 1)

and reverse the conviction under State v. Taylor, 2016- 1124, 2016- 1183 ( La.

1211116), 217 So. 3d 283, arguing that the minds of the jury were " unduly

prejudiced" because the State presented graphic testimony concerning his 2019

conviction and turned the trial into a " mini -trial" of the prior offense. The defendant

argues that the State could have proven the prior conviction without witness

testimony, and the State presented more evidence than was necessary for the limited

purpose allowed by the trial court.

Prior to trial, the State filed a notice of intent to use evidence of other crimes,

in particular, a June 12, 2019 conviction of the defendant for indecent behavior with

another juvenile, M.N. The State contended it wished to introduce evidence of the

prior conviction in the instant case, pursuant to La. C. E. art. 412.2, as evidence of the

4I her statement given to the Child Advocacy Center, S. M. referred to her vagina as her coonie" and pointed to her private parts, which the examiner understood to mean her genitalia.

3 defendant' s character for sexually assaultive behavior and/ or as having a lustful

disposition towards children.

The defendant filed a motion in limine arguing the 2019 convictions had

minimal probative value and would only serve to convince the jury he was a

dangerous person where the prior conviction involved a fourteen -year-old girl, rather

than a nine-year- old girl, and alleged a different type of assault. The State argued the

instant offense and the prior offense both involved indecent behavior with a minor

under the age of seventeen years old, and the earlier conviction demonstrated the

defendant' s lustful disposition towards children because it showed he had committed

more than one lewd and lascivious act with minors.

The trial court found La. C. E. art. 412. 2 applied because the 2019 conviction

for sexually assaultive behavior involved a minor child under the age of seventeen

years old at the time of the offense. The court noted it was unable to locate any

jurisprudence holding a different standard applied based on the age difference

between the victim in the earlier case and the victim in the instant case. The court

further determined that the probative value of the evidence of the 2019 conviction

was high and was not outweighed by the danger of unfair prejudice. Additionally,

the court noted the State' s notice complied with Article 412.2( B) by specifically

articulating the previous acts' and how they were similar to the allegations in the

instant case. Accordingly, the court held that evidence related to the 2019 conviction

would be admissible in the instant case, but it would give a limiting instruction

regarding any evidence introduced in connection with the conviction. The defendant

objected to the ruling of the court.

The motion also sought to prevent the presentation of evidence concerning an unrelated incident in which the defendant had allegedly choked his son. The State, however, did not offer evidence of that incident at trial.

6The notice set forth details of the 2019 offense consistent with the testimony of M.N., the victim in that case. Louisiana Code of Evidence article 412. 2, entitled, " Evidence of similar

Free access — add to your briefcase to read the full text and ask questions with AI

Related

State v. Moody
779 So. 2d 4 (Louisiana Court of Appeal, 2000)
State v. Miller
776 So. 2d 396 (Supreme Court of Louisiana, 2000)
State v. Martin
607 So. 2d 775 (Louisiana Court of Appeal, 1992)
State v. Allen
664 So. 2d 1264 (Louisiana Court of Appeal, 1995)
State v. Folse
623 So. 2d 59 (Louisiana Court of Appeal, 1993)
State v. Johnson
951 So. 2d 294 (Louisiana Court of Appeal, 2006)
State v. Barnes
685 So. 2d 1148 (Louisiana Court of Appeal, 1996)
STATE of Louisiana v. Gary LAYTON; State of Louisiana v. Gary Layton
168 So. 3d 358 (Supreme Court of Louisiana, 2015)
Wyker v. Texas Co.
79 So. 7 (Supreme Court of Alabama, 1918)
State of Louisiana v. Joseph Taylor
217 So. 3d 283 (Supreme Court of Louisiana, 2016)
McCoy v. Louisiana
584 U.S. 414 (Supreme Court, 2018)
State v. Gray
179 So. 3d 936 (Louisiana Court of Appeal, 2015)
State v. Wright
79 So. 3d 309 (Supreme Court of Louisiana, 2011)
State v. Papizan
255 So. 3d 572 (Supreme Court of Louisiana, 2018)
State v. Papizan
256 So. 3d 1091 (Louisiana Court of Appeal, 2017)

Cite This Page — Counsel Stack

Bluebook (online)
State Of Louisiana v. Rickey J. Lafont, Jr., Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-louisiana-v-rickey-j-lafont-jr-lactapp-2023.