State of Louisiana v. Victor Luis Avila Ramos

CourtLouisiana Court of Appeal
DecidedOctober 6, 2021
DocketKA-0021-0129
StatusUnknown

This text of State of Louisiana v. Victor Luis Avila Ramos (State of Louisiana v. Victor Luis Avila Ramos) 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. Victor Luis Avila Ramos, (La. Ct. App. 2021).

Opinion

NOT DESIGNATED FOR PUBLICATION

STATE OF LOUISIANA COURT OF APPEAL, THIRD CIRCUIT

21-129

STATE OF LOUISIANA

VERSUS

VICTOR LUIS AVILA RAMOS

**********

APPEAL FROM THE FOURTEENTH JUDICIAL DISTRICT COURT PARISH OF CALCASIEU, NO. 14773-17 HONORABLE G. MICHAEL CANADAY, DISTRICT JUDGE

CANDYCE G. PERRET JUDGE

Court composed of Elizabeth A. Pickett, John E. Conery, and Candyce G. Perret, Judges.

MANSLAUGHTER CONVICTION AND SENENCE VACATED AND REMANDED FOR NEW TRIAL; OBSTRUCTION OF JUSTICE CONVICTION AFFIRMED WITH INSTRUCTIONS. Edward Kelly Bauman Louisiana Appellate Project Post Office Box 1641 Lake Charles, LA 70602-1641 (337) 491-0570 COUNSEL FOR DEFENDANT/APPELLANT: Victor Luis Avila Ramos

Stephen C. Dwight District Attorney Post Office Box 3206 Lake Charles, LA 70601 (337) 437-3400 COUNSEL FOR APPELLEE: State of Louisiana

David S. Pipes Assistant District Attorney 901 Lakeshore Drive Lake Charles, LA 70601 (337) 437-3400 COUNSEL FOR APPELLEE: State of Louisiana PERRET, Judge.

Victor Luis Avila Ramos, Defendant, was found guilty of manslaughter, a

violation of La.R.S. 14:31, and obstruction of justice, a violation of La.R.S.

14:130.1. He was sentenced to thirty-five years at hard labor with credit for time

served, and fifteen years at hard labor, with credit for time served, respectively.

The sentences were ordered to run concurrently. He appeals the nonunanimous

verdict for the manslaughter conviction under Ramos v. Louisiana, 590 U.S. ___,

140 S.Ct. 1390 (2020), and challenges the sufficiency of the evidence for the

obstruction verdict. On appeal, we vacate Defendant’s manslaughter conviction

and remand the case for a new trial on that charge. Further, we affirm the

obstruction of justice conviction with instructions to notify Defendant of the

provisions of La.Code Crim.P. art. 930.8 within ten days of this opinion and to file

written proof in the record that Defendant received the notice.

FACTUAL AND PROCEDURAL HISTORY:

Defendant was arrested for the injury of Lauren Guidry, from which she

later died. On May 22, 2017, the Calcasieu Parish Sheriff’s Office was called to

investigate an incident at the LeBleu Mobile Home Park. The record indicates Ms.

Guidry was leaving their mobile home when an argument ensued between her and

Defendant. Ms. Guidry was subsequently pinned between the mobile home and a

vehicle Ms. Guidry stated was driven by Defendant. Ms. Guidry was brought to

Christus St. Patrick’s Hospital with extensive injuries. She later succumbed to her

injuries after being transferred to Lafayette General Hospital.

Prior to her death, Ms. Guidry gave a statement to officials while at the

hospital in which she identified Defendant by name and claimed Defendant

smashed her between the mobile home and the vehicle. Thereafter, deputies at the scene of the incident apprehended Defendant when he rode up to them on a four-

wheeler and freely gave them his name. No vehicles believed to be involved in the

incident were found at the scene, but the mobile home skirting was damaged. A

maroon vehicle was later located some distance away in a gated parking area with

a large shed or structure and behind a building labeled “LeBleau Mobile Home

Park & Mini Storage.” The vehicle had damage to the front passenger side bumper

and headlight.

Defendant was ultimately charged with manslaughter and obstruction of

justice for tampering with evidence. Defendant, a non-English speaker, was

provided a translator and, through counsel, entered pleas of not guilty to both

charges. Ultimately, Defendant expressed his desire to represent himself. The trial

court inquired into Defendant’s educational and linguistic background, warned

Defendant that he would be at a disadvantage representing himself, especially

considering the language barrier, and informed him of the seriousness of his

charges and maximum sentences. Despite this, Defendant elected to continue pro

se at trial.

During trial, Defendant was provided an interpreter and had the benefit of

stand-by counsel. The jury found Defendant guilty of manslaughter by a ten-to-

two verdict and guilty of obstruction of justice by a unanimous verdict on October

10, 2019.1

1 When the verdict was read and the jury was polled on October 10, 2019, the trial court announced the vote was eleven to one to convict Defendant of manslaughter. However, at a hearing on October 16, 2019, the trial court explained that, after the verdict was read and the jury was polled, one of the jurors indicated she had misunderstood the polling and did not realize it sought her personal verdict. She indicated she did not vote for the guilty verdict on the manslaughter charge, but she did vote guilty on the obstruction of justice charge. Thus, the verdict was correctly ten to two to convict Defendant of manslaughter and not eleven to one.

2 The trial court sentenced Defendant to serve thirty-five years at hard labor

for the manslaughter conviction. The trial court also sentenced Defendant to serve

fifteen years at hard labor for the obstruction of justice conviction. The sentences

were ordered to run concurrently.

Defendant now seeks review from this court. He alleges his nonunanimous

verdict on the manslaughter conviction is unconstitutional and that the evidence

was insufficient to convict him of obstruction of justice.

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 there

are two errors patent, one discussed below, and one which is raised and discussed

in Assignment of Error Number One.

The record before this court does not indicate that the trial court advised

Defendant of the prescriptive period for filing post-conviction relief as required by

La.Code Crim.P. art. 930.8. Thus, the trial court is directed to inform Defendant of

the provisions of Article 930.8, sending appropriate written notice to Defendant

within ten days of the rendition of the opinion, and to file written proof in the

record that Defendant received the notice. State v. Roe, 05-116 (La.App. 3 Cir.

6/1/05), 903 So.2d 1265, writ denied, 05-1762 (La. 2/10/06), 924 So.2d 163.2

ASSIGNMENT OF ERROR NUMBER ONE:

Defendant contends he is entitled to a new trial because his nonunanimous

jury verdict for manslaughter was declared unconstitutional by Ramos, 590 U.S.

___. The State agrees Defendant’s conviction and sentence for manslaughter

2 This Court notes that resentencing may not be required if Defendant is either not retried on the manslaughter charge or is acquitted after a retrial. Accordingly, this court orders written notice of the provisions of La.Code Crim.P. art. 930.8 rather than notice at resentencing.

3 should be vacated. The State further agrees the charge of manslaughter should be

remanded for a new trial.

Although the concurring justices in Ramos did not join in all parts of the

majority opinion, the Supreme Court unambiguously determined that

nonunanimous verdicts are not permitted by the Sixth Amendment to the

Constitution. The prohibition applies to the states through the Fourteenth

Amendment and applies to cases pending on direct review. Id. at p. 1397; see also

concurrences by Sotomayor, Kavanaugh, and Thomas, JJ.

Defendant’s case was still in the process of direct review at the time of the

Ramos decision.

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Related

McDaniel v. Brown
558 U.S. 120 (Supreme Court, 2010)
Jackson v. Virginia
443 U.S. 307 (Supreme Court, 1979)
State v. Mussall
523 So. 2d 1305 (Supreme Court of Louisiana, 1988)
State v. Captville
448 So. 2d 676 (Supreme Court of Louisiana, 1984)
State v. Smith
661 So. 2d 442 (Supreme Court of Louisiana, 1995)
State v. Leger
936 So. 2d 108 (Supreme Court of Louisiana, 2006)
State v. Roe
903 So. 2d 1265 (Louisiana Court of Appeal, 2005)
State v. Lubrano
563 So. 2d 847 (Supreme Court of Louisiana, 1990)
State v. Pigford
922 So. 2d 517 (Supreme Court of Louisiana, 2006)
State v. Lambert
720 So. 2d 724 (Louisiana Court of Appeal, 1998)
State v. Ryan
969 So. 2d 1268 (Louisiana Court of Appeal, 2007)
Leger v. Louisiana
127 S. Ct. 1279 (Supreme Court, 2007)
State v. Jones
983 So. 2d 95 (Supreme Court of Louisiana, 2008)
State v. Strother
49 So. 3d 372 (Supreme Court of Louisiana, 2010)
State v. Tatum
40 So. 3d 1082 (Louisiana Court of Appeal, 2010)
State v. Vercher
162 So. 3d 740 (Louisiana Court of Appeal, 2015)
State v. Matthews
200 So. 3d 895 (Louisiana Court of Appeal, 2016)
State v. Allen
742 So. 2d 949 (Louisiana Court of Appeal, 1999)
Ramos v. Louisiana
140 S. Ct. 1390 (Supreme Court, 2020)

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State of Louisiana v. Victor Luis Avila Ramos, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-louisiana-v-victor-luis-avila-ramos-lactapp-2021.