State of Louisiana Versus Evan Bradford

CourtLouisiana Court of Appeal
DecidedMarch 21, 2024
Docket23-KA-381
StatusUnknown

This text of State of Louisiana Versus Evan Bradford (State of Louisiana Versus Evan Bradford) 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 Versus Evan Bradford, (La. Ct. App. 2024).

Opinion

STATE OF LOUISIANA NO. 23-KA-381

VERSUS FIFTH CIRCUIT

EVAN BRADFORD COURT OF APPEAL

STATE OF LOUISIANA

ON APPEAL FROM THE TWENTY-FOURTH JUDICIAL DISTRICT COURT PARISH OF JEFFERSON, STATE OF LOUISIANA NO. 22-4798, DIVISION "F" HONORABLE MICHAEL P. MENTZ, JUDGE PRESIDING

March 21, 2024

FREDERICKA HOMBERG WICKER JUDGE

Panel composed of Judges Susan M. Chehardy, Fredericka Homberg Wicker, and Scott U. Schlegel

VACATED; REMANDED FHW SMC SUS COUNSEL FOR PLAINTIFF/APPELLANT, STATE OF LOUISIANA Honorable Paul D. Connick, Jr. Thomas J. Butler Darren A. Allemand Leo M. Aaron

COUNSEL FOR DEFENDANT/APPELLEE, EVAN BRADFORD Rachel Yazbeck WICKER, J.

In this criminal appeal, the State of Louisiana seeks review of the trial

court’s judgment granting defendant’s motion to quash the bill of information. For

the following reasons, we vacate the trial court judgment and remand this matter to

the trial court to reopen the motion to quash hearing.

FACTUAL AND PROCEDURAL BACKGROUND

On September 28, 2022, the Jefferson Parish District Attorney filed a bill of

information charging defendant, Evan Bradford, with unlawful presence of a sex

offender in violation of La. R.S. 14:91.2(A)(1), which provides:

A. The following acts when committed by a person convicted of a sex offense as defined in R.S. 15:541 when the victim is under the age of thirteen years shall constitute the crime of unlawful residence or presence of a sex offender:

(1) The physical presence of the offender in, on, or within one thousand feet of the school property of any public or private elementary or secondary school or the physical presence in any motor vehicle or other means of conveyance owned, leased, or contracted by such school to transport students to or from school or a school-related activity when persons under the age of eighteen years are present on the school property or in a school vehicle.

In the bill of information, the State alleged that defendant, on or about July

18, 2022, in Jefferson Parish, violated La. R.S. 14:91.2(A)(1), in that he was

present in, on, or within 1000 feet of school property while having been previously

convicted on May 22, 2015, of pornography involving juveniles in violation of La.

R.S. 14:81.1 (six counts) in Division “F” in case number 522-906 in Orleans Parish

Criminal District Court.

On December 14, 2022, defendant filed a motion to quash the bill of

information. In his motion to quash, defendant alleged that he had been previously

convicted of pornography involving juveniles under the age of 17 in violation of

La. R.S. 14:81.1, but that he had not been convicted or sentenced under the

enhanced provision applicable when the conviction is for pornography involving

23-KA-381 1 juveniles under the age of thirteen. Defendant argued that La. R.S. 14:91.2(A)

requires that the State prove that an offender was convicted of a sex offense

involving a victim under the age of thirteen. Because he alleged that he pled guilty

to pornography involving juveniles under the age of seventeen, and not to the

crime of pornography involving the sentencing enhancement applicable when the

pornography involved juveniles under the age of thirteen, defendant argued that the

State could not properly charge him under La. R.S. 14:91.2(A).

In his memorandum in support of his motion, defendant also raised due

process concerns, arguing that he had not been provided notice that he could not

enter a public park as a condition or supervision restriction following his

underlying conviction. Specifically, defendant alleged that he “signed up with the

Sex Offender registry upon his release from prison” and that “[h]e was told by the

Officer at the Sex Offender Registry in Orleans Parish that he was allowed [to]

enter parks because his crime did not involve a victim under the age of thirteen.”1

Defendant indicated that he was “[c]urrently awaiting an affidavit from Detective

Rueben Henry of the New Orleans Police Department Sex Offender Registry” to

support his claims. Defendant also raised double jeopardy concerns, contending

that the same evidence relied upon for his underlying conviction, which allegedly

arose out of a guilty plea prior to trial, would be relied upon by the State at trial in

the instant case.

The State opposed the motion to quash, asserting that La. R.S. 14:91.2(A)

should be interpreted to apply to any convicted sex offender, regardless of the

required elements of the underlying crime, when the State can prove at trial that the

underlying sex offense factually involved a victim under the age of thirteen. In its

opposition to the motion to quash, the State recognized that the issue before the

1 Neither the State nor the defense discuss whether defendant, pursuant to the terms of his guilty plea, is subject to the lifetime supervision provided for in La. R.S. 15:561.3.

23-KA-381 2 court is a res nova issue of statutory interpretation. Although the State argued that

the trial court could consider the motion to quash on the face of the bill, it

simultaneously indicated that, “[i]f this Court is unwilling to deny the Defendant’s

motion to quash at this juncture, the State would respectfully re-urge its request for

evidentiary proceedings” to oppose the motion to quash.

On March 15, 2023, the trial court conducted a hearing on the motion to

quash. At the hearing, the State requested the opportunity to introduce evidence to

oppose the motion to quash. However, the court did not rule on the motion, but

rather requested additional briefing from the parties and reset the matter for May 1,

2023.2 On that date, after a bench conference, the trial court inquired whether the

parties prepared any argument or would submit on briefs, implicitly denying the

State’s request to introduce evidence in support of its opposition to the motion to

quash.

The transcript reflects that no evidence was introduced in support of or in

opposition to the motion to quash. The record contains no certified documentation

as to the underlying conviction. The record contains no guilty plea transcript for

defendant’s underlying conviction reflecting the factual basis for the underlying

guilty plea, nor does it contain the sex offender notification documents defendant

received following his plea.

Relatedly, there appear to be factual discrepancies as to the factual basis for

the instant charged offense. The bill of information charges defendant with the

crime of presence of a sex offender “in, on, or within one thousand feet of the

school property of any public or private elementary or secondary school” in

violation of La. R.S. 14:91.2(A)(1). However, defendant—without correction,

complaint or dispute from the State—consistently throughout his pleadings, and in

2 The memorandum in support of the motion to quash filed by defense counsel and the opposition to the motion to quash filed by the State, discussed above, were both filed after the initial March 15, 2023 hearing.

23-KA-381 3 representations to this Court in oral argument, maintains that the instant charged

offense arises out of defendant’s alleged presence at a Jefferson Parish public

playground, Pontiff Playground, as prohibited under La. R.S. 14:91.2(B) only

when a defendant has been previously convicted of an aggravated offense as

defined in La. R.S. 15:541.3 This factual distinction affects the analysis in this case

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

Related

State v. Miller
319 So. 2d 339 (Supreme Court of Louisiana, 1975)
State v. Perez
464 So. 2d 737 (Supreme Court of Louisiana, 1985)
State v. Gerstenberger
255 So. 2d 720 (Supreme Court of Louisiana, 1971)
State v. Godchaux
132 So. 3d 1263 (Louisiana Court of Appeal, 2014)
State v. Whitley
169 So. 3d 658 (Louisiana Court of Appeal, 2015)

Cite This Page — Counsel Stack

Bluebook (online)
State of Louisiana Versus Evan Bradford, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-louisiana-versus-evan-bradford-lactapp-2024.