State of Louisiana v. Robert Lee Heard, Jr.

CourtLouisiana Court of Appeal
DecidedNovember 23, 2022
DocketKA-0022-0378
StatusUnknown

This text of State of Louisiana v. Robert Lee Heard, Jr. (State of Louisiana v. Robert Lee Heard, 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. Robert Lee Heard, Jr., (La. Ct. App. 2022).

Opinion

STATE OF LOUISIANA COURT OF APPEAL, THIRD CIRCUIT

KA 22-378

STATE OF LOUISIANA

VERSUS

ROBERT LEE HEARD, JR.

**********

APPEAL FROM THE TWENTY-SEVENTH JUDICIAL DISTRICT COURT PARISH OF ST. LANDRY, NO. 12-K4535-D HONORABLE D. JASON MECHE, DISTRICT JUDGE

GARY J. ORTEGO JUDGE

Court composed of Chief Judge, Sylvia R. Cooks, Charles G. Fitzgerald, and Gary J. Ortego, Judges.

AFFIRMED; REMANDED FOR CORRECTION OF SENTENCING MINUTES. Paula Corley Marx Louisiana Appellate Project P. O. Box 82389 Lafayette, LA 70598-2389 (337) 991-9757 COUNSEL FOR DEFENDANT/APPELLANT: Robert Lee Heard, Jr.

Chad Patrick Pitre District Attorney 27th JDC P.O. Box 1968 Opelousas, LA 70571 (337) 948-3041 COUNSEL FOR PLAINTIFF/APPELLEE: State of Louisiana

Kathleen E. Ryan Morrow, Morrow, Ryan P. O. Drawer 1787 Opelousas, LA 70571-1787 (337) 948-4483 COUNSEL FOR PLAINTIFF/APPELLEE: State of Louisiana ORTEGO, Judge.

A brief procedural history of this criminal proceeding is necessary as to this

appeal.

Following Defendant’s first trial on August 17, 2017, the jury found

Defendant guilty by an 11-1 jury verdict. Defendant appealed his conviction and

sentence, contending, among other things, that his conviction was illegal because of

the non-unanimous verdict. On November 7, 2018, this court affirmed Defendant’s

second-degree murder conviction and life sentence. State v. Heard, 18-236 (La.App.

3 Cir. 11/7/18), 258 So.3d 875, writ denied, 18-2013 (La. 4/29/19), 268 So.3d 1029,

and writ denied, 18-2022 (La. 4/29/19), 268 So.3d 1033. Thereafter, on April 27,

2020, the United States Supreme Court remanded that first case to this court, finding

that a unanimous verdict should have been required to find Defendant guilty,

considering its Ramos decision.1 Heard v. Louisiana, __ U.S. __, 140 S.Ct. 2713

(2020). Pursuant thereto, this court vacated Defendant’s conviction and sentence,

and remanded the matter for a new trial. State v. Heard, 18-236 (La.App. 3 Cir.

12/16/20), 309 So.3d 802.

Defendant’s second trial resulted in Defendant’s conviction of second-degree

murder, by the unanimous verdict as required by Ramos. In accordance with this

unanimous verdict, rendered on April 14, 2022, the trial court sentenced Defendant

to life imprisonment without the benefit of parole, probation, or suspension of

sentence. This appeal followed.

Defendant’s current appeal challenges the sufficiency of the evidence, as well

as a jury instruction regarding the number of votes required for acquittal

1 Ramos v. Louisiana, 590 U.S. __, 140 S.Ct. 1390 (2020). FACTS

The facts presented during this trial, conducted April 12-14, 2022, are

discussed in Assignment of Error No. 1.

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. The minutes of sentencing, however, require correction.

Although the sentencing transcript indicates the trial court imposed

Defendant’s sentence at hard labor, the minutes of sentencing do not state such.

“[W]hen the minutes and the transcript conflict, the transcript prevails.” State v.

Wommack, 00-137, p. 4 (La.App. 3 Cir. 6/7/00), 770 So.2d 365, 369, writ denied,

00-2051 (La.9/21/01), 797 So.2d 62. Accordingly, we remand this matter to the trial

court, and the trial court is ordered to amend the sentencing minutes to reflect that

Defendant’s sentence is to be served at hard labor, and the trial court is ordered to

provide the Defendant with notice of the amended sentencing minutes, within thirty

(30) days.

ASSIGNMENT OF ERROR NO. 1

In this assignment of error, Defendant contends the evidence presented at trial

meets the definition of manslaughter however was insufficient to support a

conviction of second-degree murder. In reviewing the sufficiency of evidence, this

court has set forth the standard of review as follows:

When the issue of sufficiency of evidence is raised on appeal, the critical inquiry of the reviewing court is 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 proven beyond a reasonable doubt. Jackson v. Virginia, 443 U.S. 307, 99 S.Ct. 2781, 61 L.Ed.2d 560 (1979); State ex rel. Graffagnino v. King, 436 So.2d 559 (La.1983); State v. Duncan, 420 So.2d 1105 (La.1982); State v. Moody, 393 2 So.2d 1212 (La. 1981). It is the role of the fact finder to weigh the respective credibilities of the witnesses, and therefore, the appellate court should not second guess the credibility determinations of the trier of fact beyond the sufficiency evaluations under the Jackson standard of review. See Graffagnino, 436 So.2d at 563, citing State v. Richardson, 425 So.2d 1228 (La.1983). To obtain a conviction, the elements of the crime must be proven beyond a reasonable doubt.

State v. Thacker, 13-516, p. 5 (La.App. 3 Cir. 1/28/15), 157 So.3d 798, 804 (quoting State v. Freeman, 01-997, pp. 2-3 (La.App. 3 Cir. 12/12/01), 801 So.2d 578, 580).

As for appellate review, in cases relying on circumstantial evidence, this court has stated the following:

When the conviction is based upon circumstantial evidence, La.R.S. 15:438 provides that the state “must exclude every reasonable hypothesis of innocence” in order to convict. State v. Camp, 446 So.2d 1207, 1209 (La.1984). “Circumstantial evidence consists of proof of collateral facts and circumstances from which elemental factors may be inferred according to reason, experience and common sense.” State v. Burns, 441 So.2d 843, 845 (La.App. 3 Cir.1983). However, La.R.S. 15:438 does not establish a stricter standard of review on appeal than the rational juror’s reasonable doubt standard. The statute serves as a guide for the jury when considering circumstantial evidence. On appeal, the issue is whether a rational trier of fact, when viewing the evidence in a light most favorable to the prosecution, could find that all reasonable hypotheses of innocence were excluded. State v. Williams, 13-497 (La.App. 3 Cir. 11/6/13), 124 So.3d 1236, writ denied, 13-2774 (La. 5/16/14), 139 So.3d 1024.

State v. Baumberger, 15-1056, pp. 10-11 (La.App. 3 Cir. 6/1/16), 200 So.3d 817, 826-27, writ denied, 16-1251 (La. 5/26/17), 221 So.3d 859, cert. denied, 138 S.Ct. 392 (2017).

State v. Worley, 21-688, pp. 3-4 (La.App. 3 Cir. 8/3/22), __ So.3d __.2

La.R.S. 14:30.1 defines second-degree murder as the “killing of a human

being . . . [w]hen the offender has a specific intent to kill or to inflict great bodily

harm.” La.R.S. 14:31(A) defines manslaughter as a homicide “committed in sudden

2 The Westlaw cite is 2022 WL 3051985. 3 passion or heat of blood immediately caused by provocation sufficient to deprive an

average person of his self-control and cool reflection.” The manslaughter statute

further provides that “[p]rovocation shall not reduce a homicide to manslaughter if

the jury finds that the offender’s blood had actually cooled, or that an average

person’s blood would have cooled, at the time the offense was committed.”

“Sudden passion” and “heat of blood” which distinguish manslaughter from homicide are not elements of the offense, but mitigatory factors exhibiting a degree of culpability less than is present when the homicide is committed without them. State v. Tompkins, 403 So.2d 644 (La.1981); State v. Arnold, 30,282 (La.App.2d Cir.1/21/98), 706 So.2d 578; State v.

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Related

Jackson v. Virginia
443 U.S. 307 (Supreme Court, 1979)
State v. Ruff
504 So. 2d 72 (Louisiana Court of Appeal, 1987)
State v. Richardson
425 So. 2d 1228 (Supreme Court of Louisiana, 1983)
State v. Armstrong
743 So. 2d 284 (Louisiana Court of Appeal, 1999)
State v. Tompkins
403 So. 2d 644 (Supreme Court of Louisiana, 1981)
State v. Arnold
706 So. 2d 578 (Louisiana Court of Appeal, 1998)
State v. Jackson
774 So. 2d 1046 (Louisiana Court of Appeal, 2000)
State Ex Rel. Graffagnino v. King
436 So. 2d 559 (Supreme Court of Louisiana, 1983)
State v. Massey
535 So. 2d 1135 (Louisiana Court of Appeal, 1988)
State v. Duncan
420 So. 2d 1105 (Supreme Court of Louisiana, 1982)
State v. Lombard
486 So. 2d 106 (Supreme Court of Louisiana, 1986)
State v. Mitchell
889 So. 2d 1257 (Louisiana Court of Appeal, 2004)
State v. Freeman
801 So. 2d 578 (Louisiana Court of Appeal, 2001)
State v. Wommack
770 So. 2d 365 (Louisiana Court of Appeal, 2000)
State v. Camp
446 So. 2d 1207 (Supreme Court of Louisiana, 1984)
State v. Williams
124 So. 3d 1236 (Louisiana Court of Appeal, 2013)
State v. Thacker
157 So. 3d 798 (Louisiana Court of Appeal, 2015)
State v. Baumberger
200 So. 3d 817 (Louisiana Court of Appeal, 2016)
Guinn v. Kemp
136 So. 764 (Louisiana Court of Appeal, 1931)
State v. Burns
441 So. 2d 843 (Louisiana Court of Appeal, 1983)

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