State of Louisiana v. Roderick C. Jeter

• Court: Louisiana Court of Appeal
• Decided: August 27, 2025
• Docket: 56,386-KA
• Status: Published

Opinion

Judgment rendered August 27, 2025. Application for rehearing may be filed within the delay allowed by Art. 922, La. C. Cr. P.

No. 56,386-KA

COURT OF APPEAL SECOND CIRCUIT STATE OF LOUISIANA

*****

STATE OF LOUISIANA Appellee

versus

RODERICK C. JETER Appellant

Appealed from the First Judicial District Court for the Parish of Caddo, Louisiana Trial Court No. 394,802

Honorable Donald Edgar Hathaway, Jr., Judge

LOUISIANA APPELLATE PROJECT Counsel for Appellant By: Peggy J. Sullivan

JAMES E. STEWART, SR. Counsel for Appellee District Attorney

GLENN G. CORTELLO MARGARET E. RICHIE GASKINS ASHLIN NICOLE THOMAS JASON WAYNE WALTMAN Assistant District Attorneys

Before STONE, HUNTER, and MARCOTTE, JJ. STONE, J.

This appeal arises out of the First Judicial District Court, the

Honorable Donald E. Hathaway, Jr., presiding. The defendant, Roderick

Jeter (“Jeter”), was charged with home invasion and violation of a protective

order (battery of the protected person). A unanimous jury found him guilty

of home invasion and returned a responsive verdict of guilty of a

misdemeanor violation of a protective order. Jeter was subsequently

sentenced to twenty years at hard labor for the home invasion and six

months for the violation of the protective order, to be served consecutively.

A motion to reconsider Jeter’s sentence was denied and he now appeals

asserting that his sentence is excessive. For the following reasons, we

affirm.

FACTS

The victim, Catherine O’Neal (“Catherine”), lived in Shreveport,

Louisiana with her three children — ages ten, eleven, and twelve. Catherine

met Jeter at the Salvation Army and described their relationship as friends,

who lived together between 2020-2022. In April 2020, Jeter committed

domestic abuse battery upon Catherine in the presence of one of her

children. Jeter pled guilty to that offense and was thereafter sentenced to

serve one year with the Department of Corrections. In October 2022, a

permanent protective order was issued by the court forbidding Jeter from

contacting or being around Catherine.

On the morning of April 10, 2023, Catherine was startled by the sound

of three loud raps on the front door of her residence. After excusing her

children from the living room and directing them to move to the rear of the

house, she simultaneously called 911 and retrieved a hammer from her entertainment center as she neared the front door to investigate the

disturbance. According to Catherine, the door “shot open,” after which, she

contacted the authorities for a second time. Catherine then saw Jeter coming

from the side of her house and she attempted to quickly close the door but

realized she was unable to do so because the door was completely off its

hinges. Jeter then entered Catherine’s house and began to struggle with her

to retrieve the hammer. After about a minute of “tussling,” Catherine

realized that Jeter had struck her, and she felt blood on her face and ear.

Catherine’s children were present during the assault and at least one of them

witnessed the altercation.

Shreveport Police Corporal Lakendrick O’Neal (“Cpl. O’Neal”) — no

relation to Catherine — arrived at the house almost immediately after the

assault and witnessed Jeter bent over with a hammer in his hand appearing to

repair the front door of the residence. Cpl. O’Neal noticed Catherine’s

bloody face and the swelling on the left side of her face. He further testified

that the lock on the front door appeared bent from the door apparently being

kicked in as he also saw a dent in the door. Cpl. O’Neal escorted Jeter to his

police unit where he placed Jeter in the backseat while he took a statement

from Catherine. Dash cam footage, which was shown to the jury during

trial, depicted Jeter making remarks that he would break the door off its

hinges again. Paramedics were not called to the scene — and at that point

— Catherine did not seek any medical attention. Cpl. O’Neal did not take

pictures, nor was there any photographic or medical evidence presented to

corroborate the existence or nature of any injury Catherine purportedly

sustained during the assault. Upon learning that a permanent protective

2 order was in effect, Cpl. O’Neal arrested Jeter, who was thereafter charged

with home invasion and felony violation of a protective order.

A jury trial commenced on September 12, 2024, wherein Catherine

testified that she and Jeter had been in contact more than once since the

permanent protective order went into effect — 2021 through March 2023 —

and stated that she did not contact police on those occasions. Their last

known contact was a month prior to the incident, when Catherine invited

Jeter to her home. She emphasized, however, that she had not given him

permission to come to her house on the day of the assault. Catherine

testified that she is still “somewhat” afraid of Jeter, has suffered from PTSD

since the incident, and now requires more mental health medication than she

did before the attack.

Ebony Fuller (“Fuller”), a manager of the housing authority where

Catherine resided, testified that she received a text from Catherine informing

her that she (Catherine) heard her front door being kicked in, she needed

help, and to call the police. Catherine then texted Fuller “never mind,” but

as a mandated reporter, Fuller was compelled to go over to Catherine’s home

to take an incident report. Fuller saw blood coming from Catherine’s nose

and described her demeanor as “very nervous.”

At the end of trial, Jeter was found guilty as charged for the home

invasion and the jury returned a responsive verdict of misdemeanor violation

of a protective order. Jeter’s sentencing hearing was held on October 1,

2024, wherein the trial court described his arrest history as “significant” for

domestic abuse-related crimes and violating protective orders. In applying

the 894.1 factors, the trial court considered the use of threats or actual

violence during the commission of the offense and Jeter’s criminal history as 3 aggravating factors for his sentencing. The trial court found that there was

an undue risk that Jeter would commit another crime during a period of a

suspended sentence or probation and that a lesser sentence would deprecate

the seriousness of the crime. No pretrial investigation report was ordered by

the trial court; however, prior to imposing Jeter’s sentence, the trial court

elicited some personal information and found no mitigating factors

applicable.1 Jeter was sentenced to twenty years at hard labor for the home

invasion conviction and six months for the violation of the protective order

conviction. His sentences were ordered to be served consecutively. He now

appeals.

DISCUSSION

Jeter argues that the trial court did not properly consider the art. 894.1

factors and that his sentence was unconstitutionally harsh and excessive

because it was not supported by the facts and circumstances of the offense.

The state argues that Jeter’s willingness to commit violent crimes in

the presence of children indicates his lack of understanding that his actions

enhance the seriousness of his crimes and that a sentence of twenty years is

neither grossly disproportionate to his crimes nor shocking to the

conscience.

An excessive sentence claim is reviewed by examining whether the

trial court adequately considered the guidelines established in La. C. Cr. P.

art. 894.1 and whether the sentence is constitutionally excessive. State v.

Dowles, 54,483 (La. App. 2 Cir. 5/25/22), 339 So. 3d 749; State v. Vanhorn,

1 Jeter was sentenced less than a month before his thirty-eighth birthday; he had a ninth-grade education, and he was not working at the time he was arrested. In describing his upbringing, Jeter told the trial court that his father had been in jail for most of his life, noting that he only knew his first cousins, mother, aunts, and his grandmother. Jeter did not mention any sort of relationship with his paternal family. 4 52,583 (La. App. 2 Cir. 4/10/19), 268 So. 3d 357, writ denied, 20-00745 (La.

11/19/19), 282 So. 3d 1065. First, the record must show that the trial court

took cognizance of the criteria set forth in La. Cr. C. P. art. 894.1. The

articulation of the factual basis for a sentence is the goal of La. C. Cr. P. art.

894.1, not rigid or mechanical compliance with its provisions. The trial

court is not required to list every aggravating or mitigating circumstance, so

long as the record reflects that it adequately considered the guidelines of the

article. State v. Smith, 433 So. 2d 688 (La. 1983); State v. Croskey, 53,505

(La. App. 2 Cir. 5/20/20), 296 So. 3d 1151.

The Eight Amendment of the United States Constitution and Article I

§ 20 of the Louisiana Constitution prohibit the imposition of cruel or

excessive punishment. Although a sentence falls within statutory limits, it

may be excessive. State v. Sepulvado, 367 So. 2d 762 (La. 1979). The

appellate court must determine if the sentence is constitutionally excessive.

State v. Smith, 01-2574 (La. 1/14/03), 839 So. 2d 1. To assess a claim that a

sentence violates La. Const. art. I, § 20, the appellate court must determine if

the sentence is grossly disproportionate to the seriousness of the offense or

nothing more than a purposeless and needless infliction of pain and

suffering. State v. Dorthey, 623 So. 2d 1276 (La. 1993); State v. Bonanno,

384 So. 2d 355 (La. 1980). A sentence is considered grossly

disproportionate if, when the crime and punishment are viewed in light of

the harm done to society, it shocks the sense of justice. State v. Weaver, 01-

0467 (La. 1/15/02), 805 So. 2d 166; State v. Meadows, 51, 843 (La. App.

Cir. 1/10/18), 246 So. 3d 639, writ denied, 18-0259 (La. 10/29/18) 254 So.

3d 1208. The sentencing court has wide discretion to impose a sentence

within the statutory limits, and the sentence imposed will not be set aside as 5 excessive absent a manifest abuse of that discretion. State v. Williams, 03-

3514 (La. 12/13/04), 893 So. 2d 7. On review, an appellate court does not

determine whether another sentence may have been more appropriate, but

whether the trial court abused its discretion. State v. Gaines, 54,383 (La.

App. Cir. 2/22/23), 358 So. 3d 194, writ denied, 23-00363 (La. 6/21/23), 362

So. 3d 428; State v. Tubbs, 52, 417 (La. App. 2 Cir. 11/20/19), 285 So. 3d

536, writ denied, 20-00307 (La. 7/31/20), 300 So. 3d 404, on recons., 20-

00307 (La. 9/8/20), 301 So. 3d 30, and writ denied, 20-00307 (La. 9/8/20),

301 So. 3d 30. Whoever commits the crime of home invasion shall be

imprisoned at hard labor for not less than one year nor more than thirty

years. La. R.S. 14:62.8 (B).

We find no abuse of discretion in the sentence imposed on Jeter.

Pursuant to La. C. Cr. P. art. 894.1, factors considered before imposing

sentence include but are not limited to personal history, prior criminal

history, seriousness of the offense, likelihood of rehabilitation, etc. In

sentencing Jeter, the primary factors applied by the trial court include: (1)

threats or actual violence in the commission of the offense, and (2) prior

criminal history.

Violence was inflicted upon Catherine during the invasion as she

suffered from a bloody and swollen face. Jeter disregards witness testimony

that confirms this harm by arguing that Catherine’s choice not to seek

medical attention after the attack and the absence of photographic evidence

of her injuries mitigates violence being inflicted on her. By this logic, Jeter

seemingly alludes to there being no harm to Catherine, which is woefully

inaccurate. First, testimonial evidence is sufficient to prove that violence

occurred, and harm was sustained. Secondly, Jeter completely ignores the 6 psychological damage he caused to Catherine and her children during the

commission of this offense. Specifically, that: (1) Catherine suffers from

PTSD; (2) Catherine must now use a higher dosage of medication to aid in

her mental health; (3) Catherine remains afraid of Jeter; (4) Catherine’s

children were home during the home invasion; and (5) the children

witnessed the violent attack upon their mother. Not feeling safe or secure in

certain environments or witnessing a violent assault against anyone would

be unnerving to any child at the very least — but for children to witness the

attack of their own mother, in their own home, is undoubtedly terrifying,

extremely traumatic, and will not be glossed over by us.

Jeter further argues that it was improper for the trial court to consider

violence as an aggravating factor during sentencing because the legislature,

in formulating the sentencing range, has already taken violence into

consideration as one of the elements of the offense itself. We disagree with

this construction as the element of home invasion includes the intent to use

force or violence upon the person of another. Home invasion is a general

intent crime. State v. Williams, 49,249 (La. App. 2 Cir. 10/1/14), 149 So. 3d

462, writ denied,14-2130 (La. 5/22/15), 173 So. 3d 1167. General criminal

intent is present when the circumstances indicate that the offender, in the

ordinary course of human experience, must have adverted to the prescribed

criminal consequences as reasonably certain to result from his act or failure

to act. See, La. R.S. 14:10 (2). Jeter had the requisite intent by going to

Catherine’s home (uninvited) which was prohibited by the permanent

protective order and entering (without her consent) by forcing the door off

its hinges. After entering, Jeter injured Catherine by incorporating violence

during the commission of the home invasion. Jeter notes that Catherine’s 7 continued contact with him despite the protective order in effect should have

been considered a mitigating factor in his sentencing. This court neither

overlooks Catherine’s disregard for her safety (or that of her children), nor

her blatant disregard of a court order, and apparently, the jury did not either

— when it returned a responsive verdict of misdemeanor violation of a

protective order.

A review of Jeter’s prior criminal history reveals convictions and

sentences for: (1) home invasion for which he received, and served, a five-

year sentence; (2) simple robbery for which he received probation (that was

later revoked); and (3) violation of protection orders and domestic abuse

battery with child endangerment to the current victim for which he received,

and served, a one-year sentence. Jeter has exhibited a pattern of violent

behavior toward Catherine in the presence of her children. It is abundantly

clear to us that Jeter has not responded well to noncustodial treatment. His

history of the commission of the same crimes is indeed significant (as

iterated by the trial court), and demonstrates his lack of remorse, his lack of

insight and his unlikely rehabilitation if he was ordered to serve a lesser

sentence. Due to the gravity and dangerous nature of this offense, a lighter

sentence would deprecate the seriousness of home invasion. As previously

mentioned, the maximum number of years a defendant can be sentenced for

a home invasion is thirty years. The trial court’s decision to impose a

twenty-year sentence instead of thirty years is proof of the trial court’s

consideration and weighing of Jeter’s personal history against the severity of

his repeated crimes.

Based on the record, we find that Jeter’s sentence was not grossly

disproportionate to the seriousness of his offenses. The trial court properly 8 considered the art. 894.1 factors and did not abuse its discretion in

sentencing Jeter to twenty years for home invasion.

During our review we noticed that the minutes reflect that the one-day

trial occurred on May 5, 2024, and the transcript shows the trial was held on

September 12, 2024. Where there is a discrepancy between the minutes and

the transcript, the transcript prevails. State v. Smith, 53,827 (La. App. 2 Cir.

3/3/21), 315 So. 3d 407; State v. Burns, 53,250 (La. App. 2 Cir. 1/15/20),

290 So. 3d 721. Therefore, we remand this matter to the trial court with

instructions to amend the minutes to accurately reflect the date of trial.

CONCLUSION

For the reasons expressed, we affirm Roderick Jeter’s convictions and

sentences, and this matter is remanded with instructions to amend the court

minutes consistent with this opinion.

AFFIRMED AND REMANDED WITH INSTRUCTIONS.