308 So.3d 791
La. Ct. App.2020Background
- On Nov. 19, 2017 Anthony Fletcher was found shot to death in front of 217 Meadows Dr.; detectives recovered three .45 casings at the scene and a .45 pistol under sofa cushions inside 217 Meadows. Defendant Jakorey Williams was at the scene, later detained, interviewed, and had his clothing, shoes, and DNA seized.
- Forensic testing: the gun fired the casings/projectile; DNA mixture on grip/trigger had two major contributors (Williams and another, Smith) and at least two minors; victim's DNA was found on spots of Williams’ shoe and pants. Bloodstain pattern evidence placed Williams within a few feet of the victim when the shots occurred.
- Witnesses gave conflicting accounts about who was inside/outside at the shooting; some placed Williams outside/near the victim and observed him enter the residence after shots were fired.
- Williams was charged with second-degree murder, tried, convicted by a unanimous jury on April 24, 2019, and sentenced to life at hard labor without parole, probation, or suspension of sentence.
- On appeal Williams raised (1) insufficiency of the evidence/identity, (2) suppression issues (illegal arrest, warrants), (3) denial of witnesses at the suppression hearing/right to present a defense, and pro se arguments including nonunanimous-jury/instruction, late expert disclosure, and exclusion of character evidence.
Issues
| Issue | State's Argument | Williams' Argument | Held |
|---|---|---|---|
| Sufficiency/identity (was defendant shooter or principal?) | Circumstantial + forensic evidence (DNA on gun, victim's blood on Williams’ clothing, bloodspatter placing him within feet, entry into residence where gun was found, inconsistent statements/flight) permits conviction as shooter or principal | Evidence was insufficient to identify shooter; DNA and two small blood dots alone do not prove shooting; investigation was flawed and other suspects equally plausible | Affirmed. Viewing evidence in favor of prosecution a rational juror could find guilt beyond a reasonable doubt; alternatively jury could find Williams a principal. |
| Motion to suppress (was arrest/search unlawful; should evidence be excluded?) | Search warrants for 217 Meadows and for Williams’ clothing/DNA were valid; evidence seized pursuant to warrants admissible; some statements admissible as spontaneous or post-Miranda waiver | Williams argued he was unlawfully arrested without probable cause, rendering downstream seizures/statements fruit of the poisonous tree; alleged misrepresentations in warrant affidavits required suppression | Trial court partially suppressed pre-Miranda statements but denied suppression of other statements and physical evidence. Appellate court found officers lacked probable cause for the initial arrest but search-warrant evidence survived (independent/valid warrants or excised misstatements still left probable cause). Affirmed. |
| Right to present defense at suppression hearing (quashing subpoenas for Ms. Jones & Ms. Powell) | Trial court may quash compulsory process at pretrial suppression hearings; defense had other means to present substance of those witnesses (recorded call, affidavit, transcripts) | Quashing subpoenas denied defendant ability to call relevant lay witnesses to rebut warrant affidavits and suppressed evidence | No reversible error. Court held defendant had adequate opportunity to present substance of testimony (recordings, affidavits, officer testimony), and trial court did not abuse discretion. |
| Jury instruction / pro se claims (Ramos, expert disclosure, motion in limine) | Jury verdict was unanimous; expert identified and report exchanged such that admission and testimony were not objected to; motion in limine rulings previously reviewed | Instruction allowed nonunanimous verdict (pre-Ramos law); trial by ambush due to late expert notice; exclusion of character evidence deprived right to present defense | Ramos inapplicable: verdict was unanimous so no relief. Ambush/expert notice objections not preserved (no contemporaneous objection); motion in limine issue was previously litigated (writ denied) and law-of-the-case applied. No reversible error. |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (1979) (standard for reviewing sufficiency of the evidence — whether any rational trier of fact could find guilt beyond a reasonable doubt)
- State v. Hearold, 603 So.2d 731 (La. 1992) (appellate approach when sufficiency and trial errors are both raised)
- Fisher v. State (State v. Fisher), 720 So.2d 1179 (La. 1998) (distinguishing tiers of police-citizen encounters and when seizure becomes arrest)
- Ramos v. Louisiana, 140 S. Ct. 1390 (2020) (unanimity requirement for serious-offense jury convictions; Court noted Ramos inapplicable because verdict here was unanimous)
- Leon v. United States (U.S. v. Leon), 468 U.S. 897 (1984) (good-faith exception to exclusionary rule discussed as alternative but unnecessary where warrant independently supported)
- State v. Langley, 958 So.2d 1160 (La. 2007) (structural error vs. trial error framework for harmless error analysis)