State of Louisiana v. Sean Patrick Greene

CourtLouisiana Court of Appeal
DecidedApril 30, 2025
DocketKA-0024-0650
StatusUnknown

This text of State of Louisiana v. Sean Patrick Greene (State of Louisiana v. Sean Patrick Greene) 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. Sean Patrick Greene, (La. Ct. App. 2025).

Opinion

STATE OF LOUISIANA COURT OF APPEAL, THIRD CIRCUIT

KA 24-650

STATE OF LOUISIANA

VERSUS

SEAN PATRICK GREENE

**********

APPEAL FROM THE FOURTEENTH JUDICIAL DISTRICT COURT PARISH OF CALCASIEU, NO. 2732-23 HONORABLE ROBERT WYATT, DISTRICT JUDGE

LEDRICKA J. THIERRY JUDGE

Court composed of Van H. Kyzar, Ledricka J. Thierry, and Guy E. Bradberry, Judges.

AFFIRMED. Paula C. Marx Louisiana Appellate Project P.O. Box 82389 Lafayette, LA 70598-2389 (337) 991-9757 COUNSEL FOR DEFENDANT/APPELLANT Sean Patrick Greene

Steven C. Dwight District Attorney John Eric Turner Assistant District Attorney 901 Lakeshore Drive, Suite 800 Lake Charles, LA 70601 (337) 437-3400 COUNSEL FOR APPELLEE State of Louisiana

2 THIERRY, Judge.

Defendant, Sean Patrick Greene, was convicted of two counts of armed

robbery/armed robbery with a firearm, in violation of La.R.S. 14:64 and La.R.S.

14:64.3. In total, he was sentenced to thirty-five years for both convictions.

Defendant appeals both the convictions and sentences. For the reasons that follow,

we affirm.

FACTS AND PROCEDURAL HISTORY

On November 28, 2022, an armed robbery occurred at a Subway restaurant in

Lake Charles, Louisiana. On December 5, 2022, another armed robbery occurred in

Lake Charles, Louisiana—this time at a Boost Mobile store. Workers from both

stores testified that an individual came into the store, pointed a firearm at the

workers, and demanded money. Additionally, the individual stole multiple high-end

cell phones from the Boost Mobile store. A surgical mask matching the one worn by

the perpetrator was recovered from outside the Subway store and contained DNA

that matched Defendant’s DNA. Defendant was arrested. Following Defendant’s

arrest, a search warrant was executed on his residence, and clothes matching those

worn by the suspect in the two robberies were located, as well as a firearm with a

laser attachment, five cell phones which were identified as having been stolen from

the Boost Mobile store, and a pair of shoes which matched footprints left on the

counter of the Subway restaurant.

On January 30, 2023, Defendant was charged by bill of information with three

counts of armed robbery with a firearm, in violation of La.R.S. 14:64.3. The three

counts were all related to different stores that were robbed between November 28,

2022, and December 9, 2022. An amended bill of information was filed May 8, 2023,

changing the victims of the robberies from the stores to the individuals working at the time of the robberies. On January 5, 2024, a second amended bill of information

was filed, changing the victims back to the stores and charging Defendant with

armed robbery and armed robbery with a firearm on each count, in violation of

La.R.S. 14:64 and 14:64.3. Prior to trial, the State opted to sever count three and

only tried Defendant on the first two counts.

On April 1, 2024, the State filed a “Notice of Intent to Offer Evidence of

Defendant’s Other Crimes, Wrongs, or Acts under Louisiana Code of Evidence

Article 404(B)(1).” Specifically, the State sought to introduce documents related to

a pair of armed robberies committed in Texas in July 2021 for which Defendant was

adjudicated as a juvenile and placed on probation, which was still in effect at the

time of the robberies charged in the instant case. Prior to trial on April 15, 2024, a

hearing was held on the State’s notice. Defense counsel objected to the introduction

of evidence regarding Defendant’s juvenile adjudications as being overly

prejudicial. The State’s response was that it was aware Defendant’s juvenile

adjudications could not be used for sentencing enhancement but contended “there is

no law that precludes those adjudications being used in a 404(b) evidence situation.”

The trial court ultimately allowed the evidence.

During trial, the State introduced a surveillance video related to one of the

Texas robberies. Prior to its introduction, defense counsel objected on the grounds

that the video was cumulative and the witness through whom it was introduced,

Detective Juan Olivarez, could provide testimony as to what happened during the

robbery without having to show the video. After watching the video outside the

presence of the jury, the trial court allowed the video, noting that although it was

prejudicial, the prejudice did not outweigh the probative value.

2 Following trial, a unanimous jury found Defendant guilty as charged on the

two counts of armed robbery with a firearm. On June 14, 2024, the trial court

sentenced Defendant as follows, “I am going to sentence you on each count to 20

years Department of Corrections, plus five years because of the use of a firearm, all

without benefit of probation, parole, or suspension of sentence. Ten years of each

are consecutive.” The court later clarified that its intent was for Defendant to serve

thirty-five years total. On July 12, 2024, Defendant filed a “Motion to Reconsider

Sentence,” alleging that his sentences were excessive based upon his age. On July

25, 2024, the trial court denied the motion in open court. Defendant now appeals his

convictions and sentences.

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 no errors

patent.

ASSIGNMENTS OF ERROR

Defendant alleges two assignments of error on appeal:

1. It is fundamentally unfair and a denial of due process to utilize non- criminal juvenile adjudications as 404B or “other crimes” evidence. The trial court erred in allowing the state to present to the jury an overwhelming amount of “other crimes” evidence of two juvenile adjudications, including a video purporting to show Sean Greene committing an offense in Texas when he was 16 years old. This evidence was highly prejudicial, far outweighing its probative value, in violation of Louisiana Constitution Article I, Section 16 and U.S. Constitution, Amend. 5 and 14.

2. The trial court erred in sentencing Sean Greene to serve 25 years on each count of armed robbery, with a firearm, considering his youth and potential for rehabilitation.

3 ASSIGNMENT OF ERROR NUMBER ONE:

In his first assignment of error, Defendant contends he is entitled to a new trial

because it was “fundamentally unfair and a denial of due process” for the trial court

to allow the State to utilize evidence as “other crimes evidence,” when they related

to crimes committed by Defendant when he was sixteen and living in Texas.

Specifically, Defendant objects to the fact the State introduced his prior juvenile

adjudications for armed robbery as well as a security video which law enforcement

in Texas published to YouTube in order to assist in identifying the perpetrator in one

of the robberies Defendant confessed to committing.

The issue in this assignment of error is seemingly simple: can evidence of

Defendant’s juvenile past be used against him in an adult criminal trial?

Complicating the issue is the fact that Defendant, although charged as an adult, was

still a juvenile at the time of the instant armed robberies. Admissibility of the

evidence at issue—Defendant’s two juvenile adjudications in Texas for armed

robbery, including a video showing Defendant committing one of said robberies—

is governed by La.Code Evid. art. 404(B)(1)(a), which states that:

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State of Louisiana v. Sean Patrick Greene, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-louisiana-v-sean-patrick-greene-lactapp-2025.