State v. Didier

263 So. 2d 322, 262 La. 364, 1972 La. LEXIS 5929
CourtSupreme Court of Louisiana
DecidedJune 5, 1972
Docket52009
StatusPublished
Cited by61 cases

This text of 263 So. 2d 322 (State v. Didier) is published on Counsel Stack Legal Research, covering Supreme Court of Louisiana primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State v. Didier, 263 So. 2d 322, 262 La. 364, 1972 La. LEXIS 5929 (La. 1972).

Opinions

TATE, Justice.

The defendant sheriff was previously convicted of malfeasance in office, La.R.S. 14:134. We affirmed his conviction and his sentence, three months in the parish jail and a fine of $500. State v. Didier, 259 La. 967, 254 So.2d 262 (1971). The present is a subsequent prosecution for simple robbery, La.R.S.14:65, and theft, La.R.S.14:67. The trial judge sustained the motions to quash the present charges,, and the state appeals.

The trial judge held the present prosecutions are for conduct forming a part of the basis of the previous conviction and,that the latter therefore constitutes a former jeopardy as to the present prosecutions. La.C.Cr.P. Arts. 591, 596. These subsequent prosecutions were therefore held barred by the state and federal constitutions. The State argues that the “offense” for which previously convicted is different from the offenses with which the defendant is presently charged. Therefore, the State contends that double jeopardy does-'not apply.

Pertinently, the (bill of) information for the prior malfeasance conviction charged the defendant sheriff with knowledge of the robbery and theft by four named persons of Louis Golden of $19,800 on May 9, [367]*3671970, and with failing to attempt to halt the commission of the crime or to apprehend the persons involved or to report the crimes to the district attorney.1 By the present robbery and theft informations, the defendant sheriff is himself charged with that robbery and theft of Golden’s $19,800.

Under the State’s evidence, Sheriff Didier participated in a scheme by which large sums of money were to be stolen or robbed from metal dealers. Metal dealers were to be persuaded to be interested in the illegal purchase of copper, which allegedly had been confiscated and was to be sold'by the sheriff for his personal gain. The copper was fictitious. Confidence men (the sheriff’s alleged confederates) were to interest the dealer in the transaction, to bring him to the deserted courthouse on a Saturday afternoon, and to take from the dealer the cash brought by him to pay for the copper.

The participation of the local sheriff in the game was essential to its success. lie helped the confidence men by assuring their access to the courthouse; he supplied them with a letterhead (upon which had been typed a “confiscation list” of the fictitious copper) and a badge (for one of them to pretend to be his chief deputy). Most important, the purpose of the sheriff in serving as local “fix” was to insure protection to the confidence men against being discovered or prosecuted for the crime.2 [369]*369For his participation, the sheriff was to receive ten percent of the take.

In the present instance, Golden, a metal dealer, was persuaded to buy some 26 tons of (fictitious) copper for $20,000, about half-price. Golden was informed the sheriff wanted to sell some stolen copper and pocket the money himself, and he was shown a “confiscation list” of this copper on the present sheriff’s letterhead. A bogus chief deputy (one of the confidence men), who had been familiarized with the courthouse by the actual sheriff, met Golden at the courthouse with his large sum of cash, supposedly $20,000 (actually $19,800), took him upstairs to the third floor of the deserted courthouse, and then robbed him of the money he had.

Under the malfeasance bill of information, the sheriff’s illegal conduct was his knowing concealment of the crime, known to him in advance of its commission, and his failure to prevent it or to apprehend those who committed it or to report the commission of the crime to the district attorney. (Under the evidence, this same misconduct by the sheriff forms the essential basis for the charge against him of participating as a principal in the Golden robbery or theft.)

The guarantee against double jeopardy provided by the United States Constitution3 is applicable to state prosecutions. Benton v. Maryland, 395 U.S. 784, 89 S.Ct. 2056, 23 L.Ed.2d 707 (1969). “That guarantee has been said to consist of three separate constitutional protections. It protects against a second prosecution for the same offense after acquittal. It protects against a second prosecution for the same offense after conviction. And it protects against multiple punishments for the same offense.” North Carolina v. Pearce, 395 U.S. 711, 717, 89 S.Ct. 2072, 2076, 23 L.Ed.2d 656 (1969).

Recent further elaborations of double jeopardy, likewise binding upon the states, must also be noted. As a part of the constitutional guarantee, retrial is barred of those issues determined in the defendant’s favor at the first trial, under a theory of collateral estoppel.4 Ashe v. Swenson, 397 [371]*371U.S. 436, 90 S.Ct. 1189, 25 L.Ed.2d 469 (1970). See also Harris v. Washington, 404 U.S. 55, 92 S.Ct. 183, 30 L.Ed.2d 212 (1971); Simpson v. Florida, 403 U.S. 384, 91 S.Ct. 1801, 29 L.Ed.2d 549 (1971). The same alleged crime cannot be twice punished by the same State by making identical conduct a criminal violation of the law of both the State and one of its subdivisions. Waller v. Florida, 397 U.S. 387, 90 S.Ct. 1184, 25 L.Ed.2d 435 (1970). Not directly applicable here, although of peripheral interest, Green v. United States, 355 U.S. 184, 78 S.Ct. 221, 2 L.Ed.2d 199 (1957), held that a defendant who is convicted of a lesser offense included in the original charge, and who thereafter secures reversal, may be retried only for the lesser included offense, since he was acquitted of the greater.

We should here note that in its recent collateral estoppel decisions (Ashe v. Swenson, Harris v. Washington, and Simpson v. Florida, cited above) a majority of the United States Supreme Court did not accept the view of the minority of the justices that the “same transaction” concept should govern double jeopardy determinations. Under this concept, multiple prosecutions are barred if based on one criminal episode — conduct of a continuing nature violating several statutes in the course of conduct with a common motivating intent aimed at a single goal. Comment, 65 Yale-L.J. 339, 348 (1956). Louisiana law and jurisprudence has also repeatedly refused to apply this test of double jeopardy.5

Although the issue is not free from doubt, we conclude that the recent federal interpretations applying collateral estoppel' do not, by themselves, require us to hold that the conviction of malfeasance, La.R.S.. 14:134, (knowing of but not reporting the crimes) bars prosecution of the defendant on the further charges of theft, La.R.S. 14:67 (the taking of anything of value-without the consent of the other or by fraudulent conduct) or robbery, La.R.S-.. 14:65 (theft “by use of force or intimidation”) .

The matter concluded unfavorably to the defendant by the first verdict is only that he knew of the theft, but did not report it or take any further action.

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Cite This Page — Counsel Stack

Bluebook (online)
263 So. 2d 322, 262 La. 364, 1972 La. LEXIS 5929, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-didier-la-1972.