State Of Louisiana v. Tyrone M. Sajna

CourtLouisiana Court of Appeal
DecidedSeptember 20, 2024
Docket2023KA0893
StatusUnknown

This text of State Of Louisiana v. Tyrone M. Sajna (State Of Louisiana v. Tyrone M. Sajna) 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. Tyrone M. Sajna, (La. Ct. App. 2024).

Opinion

Appealed from the 18th Judicial District Court In and for the Parish of West Raton Rouge State of Louisiana Docket No. 210535

Terri Russo Lacy

Antonio M. Clayton District Attorney Port Allen, Louisiana

t.ane Hogan LF"M

Hammond, Louisiaxa Tyrone M. Sajna MILLER, J.

On March 20, 2023, the defendant, Tyrone M. SaJJna, was charged by

amended grand jury indictment with two counts of aggravated rape of a victim

under the age of thirteen ( counts one and two), violations of La. R.S. 14: 42( A)(4),

and one count of sexual battery (count three), a violation of La. R.S. 14: 43. 1( A)( 1).

On April 15, 2021, he pled not guilty and, following a jury trial in March 2023,

to life imprisonment at hard labor without benefit of parole, probation, or

suspension of sentence on each of counts one and two, and to a concurreiM

sentence of fifty years imprisonment at hard labor without benefit of parole,

probation, or suspension of sentence on count three. The defendant ® appeall

filing both a counseled and pro se brief. For the following reasons, we affirm the

convictions and sentences.

In December of 2019, T.A.' disclosed to his father that he was molested by

the defendant, his former stepfather, when he was eight years old. After T.A.' s

disclosure, T.A.' s sister, J. G., also alleged she was molested by the defendant when

she was twelve years old. Following an investigation, the defendant was charged

In his first counseled and pro se assignments of error, the defendant argues

the evidence at trial was insufficient to support his convictions. The defendant

asserts the State failed to present sufficient evidence to support his convictions of

aggravated rape and sexual battery, as there was no physical evidence of sexua

abuse, and T.A. and J. G. failed to offer sworn testimony of the abuse. He also

I The minor victim is referenced herein only by her initials. See La. Ch.C. art. 412; La. R.S. 46: 1844( W); Uniform Rules of Louisiana Courts of Appeal, Rule 5- 2. argues the State failed to prove J. G. was under the age of thirteen years old at the

We note the defendant also assigns as error the trial court' s admission of

other crimes evidence and expert testimony. When the issues on appeal relate to

both the sufficiency of the evidence and one or more trial errors, the reviewing

court should first determine the sufficiency of the evidence. When addressing the

sufficiency of the evidence, consideration must be given to the entirety of the

evidence, including inadmissible evidence which was erroneously admitted, to

determine whether the evidence is sufficient to support the conviction. State v.

Howard, 2023- 1060 ( La. App. Pt Cir. • So. 3d 2024 Wj

A conviction based on insufficient evidence cannot stand, as it violates due

process. See U.S. Const. amend. XIV; La. • art. 1, § 2. The standard • reviel

for sufficiency of the evidence to support a conviction is whether, viewing the

evidence in the light most favorable to the prosecution, any rational trier of fact

could have found the State proved the essential elements of the crime beyond a

2789, L. Ed. 2d •, ( 1979); State v. Smith 2022- 0231 ( La. App.

11/ 4/ 22), 3 54 So. 3d 697, 700 ee also La. C. CrR art. 821 (B).

When a conviction is based on both direct and circumstantial evidence, the

reviewing court must resolve any conflict in the direct evidence by viewing that

evidence in the light most favorable to the prosecution. Smith, 354 So. 3d at 700.

When analyzing circumstantial evidence, the fact finder must be satisfied the

overall evidence excludes every reasonable hypothesis of innocence. See La. R.S.

15: 438. The facts then established by the direct evidence and inferred from the

circumstances established by that evidence must be sufficient for a rational trier of

fact to conclude beyond a reasonable doubt the defendant was guilty of every

3 essential element of the crime. Smith, 354 So. 3d at 700. This is not a separate test

for evaluating the evidence; rather, all of the evidence, both direct and

circumstantial, must be sufficient under Jackson to convince a rational juror the

defendant is guilty beyond a reasonable doubt. Howard, So. 3d at — 1.

2021 PITJMK! .

The defendant was charged with two counts of aggravated rape. Rape is

defined, in pertinent part, as " the act of .. . oral . . . sexual intercourse .. .

committed without the person' s lawful consent." La. R.S. 14: 41( A). Oral sexual

intercourse is the intentional touching of the victim' s genitals by the offender using

the offender' s mouth or tongue, or the intentional touching of the offender' s

genitals by the victim using the victim' s mouth or tongue. See La. R.S. 14: 41( 0).

At the time of the instant offenses, aggravated rape was defined, in pertinent part,

as " a rape committed ... where the anal, oral, or vaginal sexual intercourse is

deemed to be without lawful consent of the victim because it is committed ...

w]hen the victim is under the age of thirteen years." La. R.S. 14: 42( A)(4) ( prior

M Aggravated rape is a general intent crime, which means the criminal intent

necessary to sustain a conviction is established by the very doing of the proscribed

act. See La. R.S. 14: 11; State v. Curtin, 2022- 1110 ( La. App. I" Cir. 10/ 5/ 23), 376

criminal intent is present whenever there is specific intent, and also when the

circumstances indicate the offender, in the ordinary course of human experience,

must have adverted to the prescribed criminal consequences as reasonably certailz to result from his act or failure to act. La. R.S. 14: 10( 2).

2 Any act in violation of La. R.S. 14: 42 committed before August 1, 2015 shall be referred to as aggravated rape, and any act in violation of La. R.S. 14: 42 committed on or after August 1, 2015 shall be referred to as first degree rape. See La. R.S. 14: 42( E).

2 The defendant was also charged with sexual battery. At the time of the

offense, sexual battery was defined, in pertinent part, as the intentional touching of

the victim' s anus or genitals by the offender using any part of the offender' s body,

or the touching of the offender' s anus or genitals by the victim using any part of

the victim' s body, when the offender acts without the consent of the victim. La.

R.S. 14: 43. 1( A)( 1) ( prior to amendment by 2015 La. Acts No. 256, § 1). Sexua

battery is a general intent crime. Thus, the only intent necessary to sustain a

conviction is established by the very doing of the proscribed act. See La. R.S.

14: 11; State v. Strain, 2022- 0670 ( La. App. Is' Cir. 6/ l/ 23), 2023 WL 3 746992, * 6

unpublished), writ denied, 2023- 00930 ( La. 1/ 17/ 24), 377 So. 3d 243.

iiiiiIillillili III ii ll;lil,llililllilil FRIFFIN ii III SM

Children' s Advocacy Center ( CAC) statement and trial testimony. In his CAC

interview on December 18, 2019, which was introduced into evidence without

objection and played for the Jury, T.A. stated he usually slept in a bedroom wi

his twin brother but would sometimes sleep in the living room. One night, when

T.A. was eight years old, he was in the living room with the defendant, who pulled

down his pants and told T.A. to suck his penis. After T.A. complied with his

request, the defendant told T.A. not to tell his mother, R.A., what happened. T.A.

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State Of Louisiana v. Tyrone M. Sajna, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-louisiana-v-tyrone-m-sajna-lactapp-2024.