State of Louisiana Versus Maynor Ramos
24-K-479
| La. Ct. App. | Nov 8, 2024Background
- Maynor Ramos was indicted for second-degree murder, attempted second-degree murder, and obstruction of justice, stemming from a January 8, 2023, shooting at La Rumba Bar & Grill in Harvey, Louisiana.
- Eyewitnesses identified Ramos and co-defendant Morales as perpetrators who escalated a verbal argument into a shooting using two separate firearms.
- The State filed a notice under La. C.E. art. 404(B) seeking to introduce evidence of a prior July 2022 nightclub altercation involving Ramos, Morales, and alleged use of a firearm.
- Ramos opposed the motion, arguing the prior incident's probative value was outweighed by its prejudicial effect and insufficient connection to the current charges.
- After a hearing, the district court granted the 404(B) motion, allowing the State to introduce evidence of the 2022 incident as relevant to intent, modus operandi, and to rebut self-defense claims.
- Ramos sought supervisory review; the appellate court denied the writ, affirming the trial court's discretion.
Issues
| Issue | Ramos' Argument | State's Argument | Held |
|---|---|---|---|
| Admissibility of prior bad acts under 404(B) | Prior incident is too dissimilar, prejudicial, and not linked to Ramos' actions | Prior acts show pattern, intent, knowledge, absence of mistake, and rebut self-defense | Evidence admissible under 404(B); no abuse found |
| Probative value vs. prejudicial effect | Prejudicial effect outweighs limited probative value | Similarities and pattern of escalation make probative value high | Probative value not outweighed by prejudice |
| Relevance to self-defense claim | 2022 event not relevant to intent or self-defense in current case | Prior event rebuts self-defense, shows absence of mistake/accident | Evidence relevant to rebut self-defense defense |
| Standard of proof for admitting 404(B) evidence | No direct evidence connects Ramos to shooting in 2022 incident | Lower evidentiary standard applies for admissibility, circumstantial evidence sufficient | Lower standard met; circumstantial evidence adequate |
Key Cases Cited
- State v. Neveaux, 377 So.3d 749 (La. App. 5 Cir. 2023) (general bar on other crimes evidence; exceptions when independently relevant)
- State v. Jenkins, 267 So.3d 203 (La. App. 5 Cir. 2019) (abuse of discretion standard for 404(B) determinations)
- State v. Jackson, 625 So.2d 146 (La. 1993) (similar acts may be admitted to show intent)
- State v. Martin, 377 So.2d 259 (La. 1979) (other crimes evidence must prove a material issue)
- State v. Guidroz, 721 So.2d 480 (La. App. 5 Cir. 1998) (remoteness goes to weight, not admissibility)