State of Louisiana v. William Serigne & Lionel Serigne, 2016-K -1034

Background

In 2009 D.A. accused her cousins William and Lionel Serigne of childhood sexual abuse; additional family members accused William of other sexual offenses.
Initial indictments charged Lionel and William separately; after denial of the State’s motion to try together, a second grand jury returned consolidated indictments alleging joint participation for some counts.
Motions to sever were denied and the case proceeded to a bench trial; the trial court refused an in camera review of D.A.’s grand jury testimony.
The trial court convicted Lionel of aggravated rape (life without parole) and convicted William on several counts (aggregate 40 years hard labor); both were tried together.
The Fourth Circuit vacated both convictions: it found Lionel’s indictment spanned a period when aggravated rape could be capital (invoking State v. Holmes) and concluded Lionel could not validly waive a jury; it also obtained the grand jury transcript and, sua sponte, found undisclosed Brady material requiring a new trial for William.
The Louisiana Supreme Court reversed the Fourth Circuit: it reinstated both convictions and sentences, rejected application of Holmes to bar Lionel’s jury waiver (relying on later precedent like Schrader), but remanded to the district court to review the grand jury transcript for possible undisclosed Brady/Giglio/Bagley material and to allow further appellate review of joinder and other pretermitted errors.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Lionel’s indictment exposure to a historical period when aggravated rape was punishable by death made the offense "capital" so he could not waive a jury	State: capital-classification doctrine requires capital procedural safeguards where indictment spans period when death penalty applied	Lionel: he never faced death, validly waived jury, and did not raise issue below	Court: rejected Holmes-based capital-classification application; reinstated conviction and held waiver valid in these circumstances
Whether the court of appeal could sua sponte grant relief based on Brady material in grand jury transcript not considered by trial court	State: appellate court should not decide Brady claims it was never asked to rule on and based on materials outside trial record	Court of Appeal: transcript showed exculpatory evidence withheld	Court: reversed the appellate grant of new trial to William; remanded to district court to examine grand jury transcript under Brady/Giglio/Bagley before appellate factfinding
Whether joinder of trials was prejudicial given lack of evidence of joint participation at trial	William: misjoinder prejudiced him and warranted severance/new trial	State: joint-participation allegation in second indictment justified joinder; trial court did not abuse discretion pretrial	Court: trial court’s pretrial joinder decision not an abuse; preserved William’s misjoinder claim for appellate review after remand to consider grand jury material
Proper procedural path for resolving undisclosed grand jury material discovered on appeal	Appellate court exercised its discretion to obtain grand jury transcript and rule on Brady	Defendants: such claims should be presented and ruled on below first; appellate factfinding in criminal cases is constrained	Court: remanded to district court to evaluate any undisclosed Brady material; defendants may appeal unfavorable remand rulings

Key Cases Cited

Furman v. Georgia, 408 U.S. 238 (1972) (holding death-penalty schemes with unguided jury discretion unconstitutional)
Roberts v. Louisiana, 428 U.S. 325 (1976) (invalidating mandatory death penalty in certain statutes)
Selman v. Louisiana, 428 U.S. 906 (1976) (per curiam addressing mandatory death penalty for aggravated rape)
State v. Holmes, 263 La. 685, 269 So.2d 207 (La. 1972) (earlier Louisiana decision treating offenses as capital for procedural protections)
State v. Schrader, 518 So.2d 1024 (La. 1988) (rejected prior capital-classification approach and limited applicability of capital procedural presumptions)
Louviere v. State, 833 So.2d 885 (La. 2002) (clarifying that not all trial components must be decided by a jury; penalty phase is distinct)
Brady v. Maryland, 373 U.S. 83 (1963) (prosecutor must disclose materially exculpatory evidence)
Giglio v. United States, 405 U.S. 150 (1972) (prosecutorial disclosure obligations include impeachment evidence)
United States v. Bagley, 473 U.S. 667 (1985) (materiality standard for nondisclosure of evidence under Brady)