State of Louisiana v. Sebastian Brass

CourtLouisiana Court of Appeal
DecidedSeptember 27, 2023
Docket55,265-KA
StatusPublished

This text of State of Louisiana v. Sebastian Brass (State of Louisiana v. Sebastian Brass) 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. Sebastian Brass, (La. Ct. App. 2023).

Opinion

Judgment rendered September 27, 2023. Application for rehearing may be filed within the delay allowed by Art. 922, La. C. Cr. P.

No. 55,265-KA

COURT OF APPEAL SECOND CIRCUIT STATE OF LOUISIANA

*****

STATE OF LOUISIANA Appellee

Versus

SEBASTIAN BRASS Appellant

Appealed from the Fifth Judicial District Court for the Parish of Franklin, Louisiana Trial Court No. 2021555F

Honorable John Clay Hamilton, Judge

LOUISIANA APPELLATE PROJECT Counsel for Appellant By: Holli Herrle-Castillo

PENNY WISE DOUCIERE Counsel for Appellee District Attorney

CAROLINE E. HEMPHILL AMANDA M. WILKINS Assistant District Attorneys

Before STEPHENS, HUNTER, and ELLENDER, JJ.

HUNTER, J., dissents with written reasons. STEPHENS, J.

This criminal appeal arises out of the Fifth Judicial District Court,

Parish of Franklin, State of Louisiana, the Honorable John Clay Hamilton,

Judge, presiding. Defendant, Sebastian Brass, was charged by bill of

indictment with second degree murder, a violation of La. R.S. 14:30.1, and

obstruction of justice by tampering with evidence, a violation of La. R.S.

14:130.1. In accordance with a plea agreement, Brass pled guilty to

manslaughter and obstruction of justice. The trial court sentenced him to 40

years’ imprisonment at hard labor on the manslaughter conviction and 20

years on the obstruction of justice conviction, with the sentences to run

consecutively. Brass has appealed, urging excessiveness of his 60-year

cumulative sentence. Finding no error, we affirm.

FACTS/PROCEDURAL HISTORY

On August 24, 2021, Brass stabbed the victim, Kourtney Malone,1 in

the chest with a kitchen knife. Malone died as a result of the injuries

inflicted by Brass. After the stabbing, Brass gave the knife to his mother

and paid a witness to refrain from speaking to the police. In a statement to

officers, Brass admitted to stabbing Malone. He was charged by bill of

indictment with second degree murder, a violation of La. R.S. 14:30.1, and

obstruction of justice by tampering with evidence, a violation of La. R.S.

14:130.1.

On August 2, 2022, Brass and the State reached a plea agreement

whereby he agreed to plead guilty to manslaughter and obstruction of

justice, and the State agreed not to charge Brass as a habitual offender.

1 The record contains variations of the spelling of the victim’s first name, including “Kourtney,” “Kortney,” and “Courtney.” Additionally, sentencing was left to the trial court’s discretion. At the guilty

plea hearing, the State provided the following basis for the plea.2 On August

24, 2021, Brass committed the manslaughter of Kourtney Malone, and he

obstructed justice by providing a witness with “money to leave and also he

provided his mother with some knives which she put in her purse.”

In the guilty plea colloquy, the trial court determined that Brass had

completed the ninth grade and was not under the influence of alcohol or

drugs at the time of the plea. The court advised Brass that by pleading

guilty, he was waiving his rights to a jury trial, to challenge the State’s

evidence against him, to confront and cross-examine the witnesses against

him, to call witnesses on his own behalf, to testify, to remain silent, and to

appeal his conviction. Brass confirmed that he had discussed his case with

counsel, and he understood the rights that he was waiving. Brass also

acknowledged that he was pleading guilty because he was guilty, not as a

result of any threats, duress, or coercion.

The trial court sentenced Brass on October 4, 2022. Prior to imposing

sentence, the trial court denied a motion made by Brass’s attorney to take

judicial notice of and consider as a mitigating factor in sentencing the “level

of methamphetamine or other substance based on the serology in the

victim’s system at the time of his death.” The trial court complied with La.

C. Cr. P. art. 894.1 by setting forth the factors it considered and noted its

consideration of the pre-sentence investigation (“PSI”) report, law

enforcement reports, and victim impact statements on the record before

2 The Winnsboro Police Department’s Investigative Reports and the Franklin Parish Sheriff’s Office’s Arrest Report were also introduced in support of the factual basis of the plea. 2 sentencing Brass to 40 years’ imprisonment at hard labor on the

manslaughter conviction and 20 years’ imprisonment at hard labor on the

obstruction of justice conviction. The court ordered the sentences to run

consecutively under La. C. Cr. P. art. 883, “[b]ased on the detailed criminal

history of this defendant and [his] being a fourth felony offender[.]”

Brass has appealed his sentences as unconstitutionally excessive.

DISCUSSION

Brass argues that his consecutive sentences are excessive. In this

case, not only did the trial court impose the maximum penalty for each

conviction, it made the sentences consecutive. According to Brass, the

cumulative 60-year sentence is excessive by constitutional standards.

When, as in this case, a defendant fails to make a motion to reconsider

sentence, the appellate court’s review of the sentence is limited to a bare

claim of constitutional excessiveness. La. C. Cr. P. art. 881.1(E)(1); State v.

Mims, 619 So. 2d 1059 (La. 1993); State v. Taylor, 54,876 (La. App. 2 Cir.

1/11/23), 354 So. 3d 1257; State v. Cooksey, 53,660 (La. App. 2 Cir.

5/26/21), 316 So. 3d 1284, writ denied, 21-00901 (La. 10/12/21), 325 So. 3d

1074; State v. Flores, 52,639 (La. App. 2 Cir. 4/10/19), 268 So. 3d 1199,

writ denied, 19-00877 (La. 11/25/19), 283 So. 3d 496.

A sentence violates La. Const. art. I, ⸹20, if it is grossly out of

proportion to the seriousness of the offense or nothing more than a

purposeless and needless infliction of pain and suffering. State v. Smith, 01-

2574 (La. 1/14/03), 839 So. 2d 1; 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 the light of the harm done to society, it shocks the sense of justice. 3 State v. Weaver, 01-0467 (La.1/15/02), 805 So. 2d 166; State v. Flores,

supra.

La. R.S. 14:31(B) provides in part that whoever commits

manslaughter shall be imprisoned at hard labor for not more than forty years.

La. R.S. 130.1(B)(2) provides that whoever commits the crime of

obstruction of justice when the obstruction of justice involves a criminal

proceeding in which a sentence of imprisonment necessarily at hard labor for

any period less than a life sentence may be imposed, the offender may be

fined not more than fifty thousand dollars, or imprisoned for not more than

twenty years at hard labor, or both.

In sentencing Brass, the trial court made a thorough C. Cr. P. art.

894.1 analysis and noted its consideration of the PSI report, law enforcement

reports, and victim impact statements, as well as 34 letters submitted in

support of the defendant.

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

Related

State v. Dorthey
623 So. 2d 1276 (Supreme Court of Louisiana, 1993)
State v. Weaver
805 So. 2d 166 (Supreme Court of Louisiana, 2002)
State v. Bonanno
384 So. 2d 355 (Supreme Court of Louisiana, 1980)
State v. Smith
839 So. 2d 1 (Supreme Court of Louisiana, 2003)
State v. Mims
619 So. 2d 1059 (Supreme Court of Louisiana, 1993)

Cite This Page — Counsel Stack

Bluebook (online)
State of Louisiana v. Sebastian Brass, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-louisiana-v-sebastian-brass-lactapp-2023.