State of Louisiana v. Joseph Taylor
2016 La. LEXIS 2472
| La. | 2016Background
- Joseph Taylor was charged with possession with intent to distribute (PWITD) cocaine and conspiracy; the State filed Prieur notices seeking to admit three prior cocaine convictions as "other crimes" evidence.
- The State first sought admission of a 1999 PWITD conviction (police report attached; State asserted a guilty plea). The district court held a Prieur hearing and allowed that evidence.
- The State later amended its notice to add 1998 and 2005 guilty pleas to possession of cocaine (police reports attached); the district court ruled these admissible without a separate pre‑trial evidentiary hearing.
- Taylor challenged both rulings by writ; this Court granted review to clarify the burden and procedure for admitting other‑crimes evidence under La. C.E. art. 404(B).
- The Court affirmed admission of the 1999 PWITD conviction (finding sufficient preliminary proof and probative value for intent) but reversed the ruling as to the 1998 and 2005 possession convictions and remanded for a required pre‑trial Prieur hearing.
Issues
| Issue | Plaintiff's Argument (State) | Defendant's Argument (Taylor) | Held |
|---|---|---|---|
| Proper burden of proof to admit other‑crimes evidence under La. C.E. art. 404(B) | Article 1104 aligns Louisiana with Fed. R. Evid. 404; only sufficient evidence to allow a jury to find the act occurred is required (no clear‑and‑convincing standard) | Prieur requires a clear and convincing showing to protect defendants from undue prejudice | State need only show sufficient evidence to support a jury finding the other act occurred (Huddleston/104(b) standard) |
| Whether a pre‑trial evidentiary (Prieur) hearing is required | Huddleston suggests no mandatory pre‑trial evidentiary burden; the court may follow federal practice | Prieur contemplated a Prieur hearing to protect constitutional rights and requires pre‑trial determination | Louisiana requires a pre‑trial Prieur hearing (trial courts retain gatekeeping role), though it should not be a mini‑trial |
| Sufficiency of unauthenticated police report at Prieur hearing | A police report attached to the notice is sufficient under relaxed evidentiary rules at a Prieur hearing | An unauthenticated report is insufficient; defendant should be allowed to subpoena witnesses to rebut | Unaudited police report may be considered at a Prieur hearing under La. C.E. art. 104(A); here it was sufficient combined with referenced guilty plea for the 1999 PWITD matter |
| Admissibility of 1999 PWITD vs. 1998/2005 possession convictions | 1999 PWITD is relevant to specific intent; 1998/2005 are similar and should also be admitted | 1998/2005 possession convictions differ (not PWITD) and admitting them without a hearing is prejudicial | 1999 PWITD admissible (probative for intent and not unduly prejudicial); admission of 1998/2005 convictions reversed and remanded for a Prieur hearing |
Key Cases Cited
- State v. Prieur, 277 So.2d 126 (La. 1973) (establishes pretrial notice, relevancy, and Prieur hearing principles for other‑crimes evidence)
- Huddleston v. United States, 485 U.S. 681 (U.S. 1988) (holding preliminary admissibility requires only evidence sufficient for a jury to find the other act occurred under Rule 104(b))
- State v. Scales, 655 So.2d 1326 (La. 1995) (recognizes relaxed evidentiary rules at Prieur hearings and court’s ability to consider hearsay)
- State v. Hearold, 603 So.2d 731 (La. 1992) (describes factors useful to infer intent to distribute in drug cases)