State v. Adams
119 So. 3d 46
La. Ct. App.2013Background
- Indictment Jan. 18, 2007 for second-degree murder of Brandon Spincer; trial December 1–3, 2009; jury verdict guilty; sentencing life imprisonment without parole; appeal timely filed.
- Defendant had a tumultuous relationship with Charla Bell; Bell dated the victim, Brandon Spincer, in late 2006; on Nov. 20, 2006, the murder occurred in a Jefferson Parish area where Bell and the victim’s vehicle were involved.
- Witnesses placed the defendant at the scene or in proximity: Charla Bell, Charla Bell’s friends Ms. Stamps and Ms. Hall identified defendant from photo lineups; neighbor Brumfield and coworker Chisesi corroborated presence and clothing.
- Post-arrest, defendant gave two statements: a denial, then a confession alleging self-defense; he claimed coercion by Detective Meunier and sought to challenge the confession.
- Defense sought to introduce evidence of a separate false confession by Detective Meunier in an unrelated case to impeach his credibility and to prove a habit of coercing confessions; the trial court limited this evidence.
- Defense also sought to cross-examine Charla Bell about post-m murder conversations and for defendant to testify about conversations with Bell; the court allowed some cross-examination but later ruled certain lines of questioning inadmissible.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Admissibility of false-confession evidence to impeach detective | Wicker; impeachment of Meunier and habit evidence allowed | Admissible under 607(D) and 406 to attack credibility and show habit | No reversible error; exclusion proper under 608/ substrates; credibility impact insufficient |
| Right to present defense via post-murder conversations | Defendant denied defense by restricting cross-examination of Bell | Testimony about Bell’s statements admissible for impeachment; some exclusion erroneous | Error in excluding testimony; harmless beyond a reasonable doubt given overwhelming evidence |
Key Cases Cited
- State v. Magee, 103 So.3d 285 (La. 2012) (trial court evidentiary rulings reviewed for abuse of discretion)
- State v. Hollins, 704 So.2d 307 (La.App.5 Cir. 1997) (extrinsic evidence to impeach credibility restricted by 608(B))
- State v. Cousin, 710 So.2d 1065 (La. 1998) (prior inconsistent statements admissible for impeachment under 607(D)(2))
- State v. Juniors, 915 So.2d 291 (La. 2005) (credibility evidence balancing; undue prejudice)
- State v. Massey, 97 So.3d 13 (La.App.5 Cir. 2012) (harmless-error standard for trial-court mistakes)
- State v. Stewart, 65 So.3d 771 (La.App.5 Cir. 2011) (indeterminate-sentence harmless where statute mandates hard labor)