State of Louisiana Versus Larry St. Amant, Jr.

CourtLouisiana Court of Appeal
DecidedSeptember 24, 2025
Docket25-K-365
StatusUnknown

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State of Louisiana Versus Larry St. Amant, Jr., (La. Ct. App. 2025).

Opinion

STATE OF LOUISIANA NO. 25-K-365

VERSUS FIFTH CIRCUIT

LARRY ST. AMANT, JR. COURT OF APPEAL

STATE OF LOUISIANA

September 24, 2025

Linda Tran First Deputy Clerk

IN RE LARRY ST. AMANT, JR.

APPLYING FOR SUPERVISORY WRIT FROM THE TWENTY-FOURTH JUDICIAL DISTRICT COURT, PARISH OF JEFFERSON, STATE OF LOUISIANA, DIRECTED TO THE HONORABLE DONALD A. ROWAN, JR., DIVISION "L", NUMBER 24-2266

Panel composed of Judges Fredericka Homberg Wicker, Jude G. Gravois, and Scott U. Schlegel

WRIT DENIED

Relator, Larry St. Amant, Jr., seeks supervisory review of the trial court’s

July 9, 2025 ruling denying his motion to suppress evidence. For the following

reasons, the writ is denied.

On April 24, 2024, the Jefferson Parish District Attorney filed a bill of

information charging relator with possession with intent to distribute cocaine

weighing 28 grams or greater in violation of La. R.S. 40:967(A).1 Relator filed a

motion to suppress evidence on October 10, 2024. Following a hearing on July 9,

2025, the trial court denied the motion to suppress.

At the July 9, 2025 suppression hearing, Detective Jeremy Budo of the

Jefferson Parish Sheriff’s Office testified that in early 2025, he received

1 Larry J. St. Amant, Sr. was charged in count two in the same bill with possession of cocaine weighing less than 2 grams in violation of La. R.S. 40:967(C). The companion writ application of St. Amant, Sr. is filed in Case Number 25-K-371.

25-K-365 information from a reliable confidential informant that St. Amant, Jr. was

trafficking cocaine in Jefferson Parish. The informant provided a description and

phone number for St. Amant, Jr., and indicated that he frequently hid cocaine

under his testicles. Surveillance was conducted, and a controlled buy was

arranged, confirming the informant’s information. Sometime thereafter, on March

5, 2024, detectives observed St. Amant, Jr. arrive at his residence on Fig Street in a

red Lexus SUV, exit the front passenger seat, go inside, and return a short time

later to the front passenger seat of that vehicle, after which they followed the

vehicle and stopped it for a traffic violation. Relator does not challenge the stop.

Instead, relator argues that his Fourth Amendment rights were violated when

he was removed from the vehicle and strip searched on the side of the road without

probable cause. Specifically, relator argues that the search exceeded the scope of a

Terry frisk, was not conducted incident to an arrest, and was based on outdated

information from a confidential informant, rather than any immediate evidence of

criminal activity.

The State, however, argues that during the stop, officers smelled marijuana

and were informed by the driver, Crystal Royal, that illegal narcotics were present

in the vehicle. A K-9 unit was also deployed and discovered marijuana in the

vehicle. Further, the State argues that during the initial search, they found

vegetative matter in St. Amant, Jr.’s pocket before conducting an additional search

that led to the discovery of cocaine under his testicles. Thus, the State argues that

the search of the defendant on the side of the road was lawful.

The trial court is vested with great discretion when ruling on a motion to

suppress. State v. McCarthy, 21-153 (La. 4/20/21), 313 So.3d 1234, 1236. The

trial court’s findings of fact on a motion to suppress are reviewed under a clearly

erroneous standard. Id.

2 Both the Fourth Amendment to the Constitution of the United States and

Article I, § 5 of the Louisiana Constitution protect individuals from unreasonable

searches and seizures. State v. Roche, 05-237 (La. App. 5 Cir. 4/25/06), 928 So.2d

761, 765, writ denied, 06-1566 (La. 1/8/07), 948 So.2d 120. Warrantless searches

and seizures are unreasonable per se unless justified by one of the specific

exceptions to the warrant requirement. Id.

In Terry v. Ohio, 392 U.S. 1, 88 S.Ct. 1868, 20 L.Ed.2d 889 (1968), the

United States Supreme Court recognized the investigatory stop as an exception to

the warrant requirement. A police officer may stop an individual if he reasonably

suspects that criminal activity may be afoot. Id. “Once an officer conducts an

investigatory stop of a person pursuant to La. C.Cr.P. art. 215.1(B), the officer may

conduct a limited pat-down frisk for weapons if he reasonably believes he is in

danger or that the suspect is armed.” State v. Gilbert, 23-121 (La. App. 5 Cir.

11/8/23), 377 So.3d 378, 387, writ denied, 23-1640 (La. 5/29/24), 385 So.3d 704.

It is not necessary that an officer establish that it was more probable than not that

the detained individual was armed and dangerous; it is sufficient that the officer

establishes a “substantial possibility” of “danger.” State v. Gresham, 97-1158 (La.

App. 5 Cir. 4/15/98), 712 So.2d 946, 952, writ denied, 98-2259 (La. 1/15/99), 736

So.2d 200.

In a hearing on a motion to suppress evidence seized without a warrant, the

State bears the burden of proving that an exception to the warrant requirement

applies. State v. Lane, 09-179 (La. App. 5 Cir. 9/29/09), 24 So.3d 920, 923, writ

denied, 09-2360 (La. 5/21/10), 36 So.3d 226 (citing La. C.Cr.P. art. 703(D)).

But here, the State has failed to carry its burden. The State called only one

witness, Detective Budo, who did not arrive on the scene until approximately 30

minutes after the traffic stop. As a result, this Court is left with what can be

observed in the videos to fill in some critical gaps in his testimony. And as noted

3 by both the State and the defense, establishing a proper timeline is essential for our

review.

After viewing the three videos, this Court finds that relator was removed

from the vehicle before any other occupant. While on the passenger side of the

vehicle, the detective conducted a brief pat down of the relator before searching his

pockets and removing what appears to be a cell phone. Relator was then

handcuffed and advised of his Miranda rights. The detective next relocated with

relator to a unit behind the subject vehicle to conduct a second search. It is at this

point that a detective can be heard announcing that he had found a little marijuana

after searching one of relator’s pockets. The videos show the detective then took

relator to the side of the unit behind the unit’s door so that they were not visible

from the street to conduct a more thorough search. The strip search itself was not

shown on the bodycam footage.

The State failed to provide any evidence, however, that the driver had yet

admitted to the presence of narcotics or that the K-9 sweep had occurred prior to

the searches of relator. In fact, one of the detectives on the video can be heard

asking if there was anything else in the car and saying that they were going to

deploy the K-9 while relator is being searched for the second time. Additionally,

the detective who conducted the pat down did not testify. As a result, we cannot

determine if the detective felt something in St. Amant, Jr.’s pocket that he

immediately recognized, based upon his experience, as a weapon or illegal

narcotics. And there was no testimony by Detective Budo on this point. Finally,

the confidential informant’s tip was not related to this date or vehicle in question.

Thus, we find that the searches of St. Amant, Jr.

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Related

Terry v. Ohio
392 U.S. 1 (Supreme Court, 1968)
Nix v. Williams
467 U.S. 431 (Supreme Court, 1984)
Murray v. United States
487 U.S. 533 (Supreme Court, 1988)
State v. Lane
24 So. 3d 920 (Louisiana Court of Appeal, 2009)
State v. Lee
976 So. 2d 109 (Supreme Court of Louisiana, 2008)
State v. Roche
928 So. 2d 761 (Louisiana Court of Appeal, 2006)
State v. Vigne
820 So. 2d 533 (Supreme Court of Louisiana, 2002)
State v. Gresham
712 So. 2d 946 (Louisiana Court of Appeal, 1998)

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