State of Louisiana v. Thomas Ledbetter

CourtLouisiana Court of Appeal
DecidedSeptember 22, 2021
Docket54,050-KA
StatusPublished

This text of State of Louisiana v. Thomas Ledbetter (State of Louisiana v. Thomas Ledbetter) 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. Thomas Ledbetter, (La. Ct. App. 2021).

Opinion

Judgment rendered September 22, 2021. Application for rehearing may be filed within the delay allowed by Art. 922, La. C. Cr. P.

No. 54,050-KA

COURT OF APPEAL SECOND CIRCUIT STATE OF LOUISIANA

*****

STATE OF LOUISIANA Appellee

versus

THOMAS LEDBETTER Appellant

Appealed from the First Judicial District Court for the Parish of Caddo, Louisiana Trial Court No. 360,355

Honorable Charles Gordon Tutt, Judge

LOUISIANA APPELLATE PROJECT Counsel for Appellant By: Sherry Watters

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

TOMMY JAN JOHNSON BRITTANY V. ARVIE Assistant District Attorneys

Before THOMPSON, ROBINSON, and HUNTER, JJ. THOMPSON, J.

Thomas Ledbetter appeals his conviction of residential contractor

fraud and subsequent sentence, alleging a fatal deficiency in the bill of

information charging him because it lacked a required statement of the grade

of the offense. The state acknowledges this deficiency in the bill of

information, which rendered the evidence insufficient to support Ledbetter’s

conviction. For the following reasons, we reverse Ledbetter’s conviction

and vacate his sentence.

FACTS

As the parties agree that the bill of information charging Thomas

Ledbetter (“Ledbetter”) is fatally deficient and his resulting conviction must

be reversed, the facts of this matter will be presented in summary. Ledbetter

was hired by Michael Shaw (“Shaw”) to build a shop for Shaw’s business

and do some improvements on his home. After a meeting in April 2018, the

two verbally agreed that Ledbetter would: (1) fix a front porch on Shaw’s

house; (2) build a rear porch on Shaw’s house; and (3) build a metal shop on

a concrete slab for Shaw to use for his mechanic business. Shaw and

Ledbetter agreed that Shaw would pay for the materials, and as partial

payment for the labor, Shaw would fix Ledbetter’s truck. This was the

extent of the agreement. Things went poorly from this point.

Ledbetter quoted Shaw a price for labor of $8 per square foot for the

28 feet by 28 feet shop. In addition, the cost for the shop materials would be

$6,272 and the cost for the concrete slab would be $3,920. Ledbetter also

quoted Shaw $4,300 for the back porch and roof and said he would do the

front porch for free in exchange for Shaw fixing his truck. The price for materials totaled $14,492 and Ledbetter required $9,000 to begin the project,

which Shaw paid.

What ensued was a series of text messages between Ledbetter and

Shaw regarding the purchase of the materials and delivery to Shaw’s

property. A death in Ledbetter’s family resulted in him having someone else

do some work on Shaw’s project, which was substandard. Shaw requested

Ledbetter alter the order in which the project would be completed. Ledbetter

requested Shaw pay for additional materials. Weather and other delays

further strained the relationship between Shaw and Ledbetter, which was

exacerbated by Shaw’s belief that he should not pay in advance for labor yet

to be performed by Ledbetter.

When Shaw did not respond to Ledbetter’s repeated request for

payment for labor, a heated argument on this matter ensued, and the police

were contacted and responded. Ledbetter complained that he had not been

paid for any of his labor and no work had been done on his truck. The

officers who responded stated that it was a civil matter and allowed

Ledbetter to remove some of the metal from the shop and take it with him.

Ledbetter was not allowed back on the property. Shaw’s complaints

ultimately resulted in Ledbetter being charged, tried and convicted of

residential contractor fraud. This appeal followed.

DISCUSSION

Ledbetter has asserted one assignment of error with five subparts as

detailed below.

Assignment of Error Number One: The State failed to prove beyond a reasonable doubt that Thomas Ledbetter committed residential contractor fraud.

2 A. The bill of information did not state a value to establish the grade of the offense, requiring reversal.

B. Where the defendant was hired to build a mechanics shop for the property owner to conduct his mechanics business, the element of the job being “residential construction” was not proven; the jury was not given the proper legal definition.

C. The value of the mechanics shop construction does not meet the legal level to require a license

D. There was no written contract and no meeting of the minds as to terms so there was no valid contract.

E. A dispute over time and money in which the property owner, not the contractor, stops the construction, is insufficient to establish fraud or misappropriation. Criminal fraud requires an intent to take unearned money. Where the property owner received goods, labor and service after a contractor actively attempts completion of the agreement, as he understood it, there is no criminal fraud.

While Ledbetter details multiple subparts to his single assignment of

error, addressing the error patent embodied in the deficiencies contained in

the bill of information failing to designate the grade of the offense charged

pretermits any consideration of the other errors asserted. In accordance with

La. C.Cr.P. art. 920, all appeals are reviewed for errors patent on the face of

the record. After reviewing the record, we find there is an error patent that

requires we reverse Ledbetter’s conviction and that his sentence be set aside.

La. R.S. 14:202.1 provides in pertinent part:

A. Residential contractor fraud is the misappropriation or intentional taking of anything of value which belongs to another, either without the consent of the other to the misappropriation or taking, or by means of fraudulent conduct, practices, or representations by a person who has contracted to perform any home improvement or residential construction, or who has subcontracted for the performance of any home improvement or residential construction. A misappropriation or intentional taking may be inferred when a person does any of the following:

3 (1) Fails to perform any work during a forty-five-day period of time or longer after receiving payment, unless a longer period is specified in the contract. (2) Uses, or causes an agent or employee to use, any deception, false pretense, or false promise to cause any person to enter into a contract for home improvements or residential construction.

(3) Damages the property of any person with the intent to induce that person to enter into a contract for home improvements or residential construction.

(4) Knowingly makes a material misrepresentation of fact in any application for a permit required by state, municipal, or parochial law.

(5) Knowingly makes a material misrepresentation of fact in any lien placed upon the property at issue.

(6) Fails to possess the required license for home improvements or residential construction required by applicable state, municipal, or parochial statute.

(7) Knowingly employs a subcontractor who does not possess the required license by applicable state, municipal, or parochial statute.

B. For purposes of this Section, “home improvement or residential construction” means any alteration, repair, modification, construction, or other improvement to any immovable or movable property primarily designed or used as a residence or to any structure within the residence or upon the land adjacent to the residence.

The designation of the various grades of violation of La. R.S.

14:202.1 and the corresponding penalties resulting therefore from are

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State of Louisiana v. Thomas Ledbetter, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-louisiana-v-thomas-ledbetter-lactapp-2021.