State of Louisiana v. Tobias Williams

CourtLouisiana Court of Appeal
DecidedSeptember 27, 2023
Docket55,290-KA
StatusPublished

This text of State of Louisiana v. Tobias Williams (State of Louisiana v. Tobias Williams) 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. Tobias Williams, (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. 55,290-KA

COURT OF APPEAL SECOND CIRCUIT STATE OF LOUISIANA

*****

STATE OF LOUISIANA Appellee

versus

TOBIAS WILLIAMS Appellant

Appealed from the First Judicial District Court for the Parish of Caddo, Louisiana Trial Court No. 360,400

Honorable Chris Victory, Judge

LOUISIANA APPELLATE PROJECT Counsel for Appellant By: G. Paul Marx

TOBIAS WILLIAMS Pro Se

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

WILLIAM JACOB EDWARDS KODIE K. SMITH BRITTANY B. ARVIE JOHN CLAUDE PHILLIPS Assistant District Attorneys

Before STEPHENS, HUNTER, and ELLENDER, JJ.

HUNTER, J., concurs in part and dissents in part with written reasons. ELLENDER, J.

The defendant, Tobias Williams, was convicted of aggravated flight

from an officer, and subsequently adjudicated a fourth felony offender and

sentenced to life imprisonment. Williams now appeals his habitual offender

adjudication and sentence. For the following reasons we affirm Williams’s

conviction and fourth felony offender status, but vacate his sentence and

remand for resentencing.

FACTS

Around 3:40 a.m. on August 17, 2018, Shreveport Police Department

(“SPD”) Officer Corey Rabalais was on patrol in the Highland-Stoner Hill

neighborhood of Shreveport when he observed an SUV with an obscured

license plate driving down Stoner Avenue. Officer Rabalais initiated a

traffic stop by turning on his lights and siren, then pulling his patrol car

behind the SUV; however, the driver, later identified as Tobias Williams,

refused to comply and continued to drive away. A chase ensued during

which Williams committed numerous traffic violations recorded by Officer

Rabalais’s dash camera in his patrol car. The footage showed multiple 25

and 35 mph speed limit signs on the roads which Williams traveled. The

footage further revealed Officer Rabalais was driving at times in excess of

60 mph in order to keep up with Williams. Williams is also seen operating

his vehicle on the wrong side of the road, failing to stop at multiple red

lights, and driving through numerous stop signs.

During this high-speed pursuit, Officer Rabalais was joined by

Corporal Jon Smith, also with the SPD. Cpl. Smith’s dash camera recorded

footage of a bicyclist on the same street as Williams and Officer Rabalais;

however, Williams and Officer Rabalais turned before ever reaching the bicyclist’s position. Additionally, both recordings reflect this high-speed

chase lasted about 15 minutes, having occurred between 3:40 a.m. and 3:55

a.m. that morning.

Williams eventually encountered a construction roadblock which

forced him to stop his SUV. He immediately exited the vehicle and fled on

foot, but Officer Rabalais was unable to catch up to him. Another SPD

officer joined in the foot chase and, after spotting Williams, gave verbal

commands to put his hands up and get down on the ground, which Williams

ignored. At some point during the chase, Sergeant Dan Sawyer, a K9 officer

with the SPD, arrived to help apprehend Williams. Sgt. Sawyer’s K9 was

able to detain Williams by biting his arm and holding on until Sgt. Sawyer

arrived. He was arrested, then transported to the hospital for treatment of his

dog bite wounds.

PROCEDURAL HISTORY

Following arrest, Williams was charged by bill of information with

one count of aggravated flight from an officer, La R.S. 14:108.1(C). Jury

trial began on December 14, 2021, and resulted in Williams’s conviction as

charged.

The state then filed an habitual offender bill of information asserting

Williams’s new conviction for aggravated flight from an officer was his

fourth felony offense, La. R.S. 15:529.1. Williams’s three prior felony

convictions were listed as follows:

1) January 28, 2008, guilty plea to Illegal Possession of Stolen Things;

2) February 11, 2016, guilty plea to Aggravated Battery; and

3) February 11, 2016, guilty plea to Illegal Possession of Stolen Firearms. 2 In a motion to quash, Williams argued his two February 11, 2016, guilty

pleas should only be treated as one prior felony conviction. On May 19,

2022, the trial court held a multiple offender hearing and found Williams

was a fourth felony offender. The trial court, noting its consideration of La.

R.S. 15:529.1, concluded the events which led to Williams’s February 11,

2016, convictions were not connected, were not a single criminal episode,

and would be treated as two separate felony convictions.

SENTENCING

On June 20, 2022, Williams was sentenced to life imprisonment at

hard labor without the benefit of probation or suspension of sentence, La.

R.S. 15:529.1(A)(4)(a). The trial court first listed Williams’s prior felony

convictions and reiterated its finding Williams was a fourth felony habitual

offender. The trial court also noted two of Williams’s four felony

convictions were for crimes of violence, aggravated battery and the instant

conviction for aggravated flight from an officer, La. R.S. 14:2(B)(5) and

(39). In support of the life sentence, the trial court stated it had considered

the sentencing guidelines, then thoroughly detailed Williams’s extensive

criminal record, expressed its belief Williams was not remorseful, and

concluded Williams did not understand the seriousness of his crimes, nor

would he in the future. The trial court also issued written reasons for

judgment.

After sentencing, Williams filed a motion to reconsider, which was

subsequently denied. This appeal followed.

3 DISCUSSION

Habitual Offender Status

In his first assignment of error, Williams argues he should only be a

third felony offender because his February 11, 2016, convictions for both

aggravated battery and illegal possession of stolen firearms occurred on the

same day, and should have been treated as just one prior felony for habitual

offender purposes.

La. R.S. 15:529.1(A) defines who is an habitual offender, and then

goes on to provide the various sentencing enhancements depending on the

total number of felony convictions:

A. Any person who, after having been convicted within this state of a felony, or who, after having been convicted under the laws of any other state or of the United States, or any foreign government of a crime which, if committed in this state would be a felony, thereafter commits any subsequent felony within this state, upon conviction of said felony, shall be punished as follows…

For a defendant to receive an enhanced penalty under La. R.S. 15:529.1, the

state must prove prior felony convictions and that the defendant is the same

person who committed the prior felonies. State v. Brown, 11-1656 (La.

2/10/12), 82 So. 3d 1232. Both the identity of the defendant, and the prior

convictions alleged, must be proved beyond a reasonable doubt. La. R.S.

15:529.1(D)(1)(b). The Louisiana Supreme Court has consistently held that

the state is not required to use a specific type of evidence to carry its burden

at a habitual offender hearing. Rather, prior convictions may be proved by

any competent evidence. State v. White, 13-1525 (La. 11/8/13), 130 So. 3d

298. Various methods of proof establishing identity have been recognized

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Related

State Ex Rel. Porter v. Butler
573 So. 2d 1106 (Supreme Court of Louisiana, 1991)
State v. Cass
17 So. 3d 486 (Louisiana Court of Appeal, 2009)
State v. Payton
810 So. 2d 1127 (Supreme Court of Louisiana, 2002)
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. Jones
398 So. 2d 1049 (Supreme Court of Louisiana, 1981)
State v. Williams
893 So. 2d 7 (Supreme Court of Louisiana, 2004)
State v. Shaw
969 So. 2d 1233 (Supreme Court of Louisiana, 2007)
State v. Smith
433 So. 2d 688 (Supreme Court of Louisiana, 1983)
State v. Lanclos
419 So. 2d 475 (Supreme Court of Louisiana, 1982)
State v. White
130 So. 3d 298 (Supreme Court of Louisiana, 2013)
State v. Meadows
247 So. 3d 1018 (Louisiana Court of Appeal, 2018)

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State of Louisiana v. Tobias Williams, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-louisiana-v-tobias-williams-lactapp-2023.