State v. Adams, 89 So. 3d 435

Blake G. Adams appeals his convictions for simple criminal damage to property and unauthorized entry of an inhabited dwelling.
Adams was originally sentenced to two years on count one and six years on count two, to run concurrently.
A later hearing under LSA-R.S. 15:529.1 found Adams to be a fourth felony offender, resulting in a 30-year enhanced sentence consecutive to count one.
The offenses arose from a relationship with the victim, Nateryl Butler, including July 13, 2008 entry after a dispute and September 24, 2008 vandalism to her car.
Deputy observations and 911 recordings were introduced; Adams denied being present at the incidents.
The trial court admitted testimony of prior domestic-violence incidents under 404(B); Adams challenges sufficiency and admissibility.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of the evidence	State argues the evidence, including victim testimony and physical evidence, proves both offenses beyond reasonable doubt.	Adams contends the State failed to prove he committed the offenses and questions Butler's credibility.	Sufficient evidence supports both convictions; rational juror could find guilt beyond a reasonable doubt.
Admissibility of other crimes evidence under 404(B)	State contends prior domestic-violence incidents are probative of motive/relationship and admissible.	Adams argues several acts were insufficient or unduly prejudicial and that probative value is outweighed by prejudice.	Court did not abuse discretion; evidentiary value outweighed prejudicial effect; limiting instruction given.
Harmlessness of potential 404(B) error	State maintained admissible other crimes were highly probative to motive and relationship.	Adams claims the admission of some acts lacking corroboration prejudiced the trial.	Even if improper, any error is harmless; verdict supported by substantial evidence independent of 404(B) evidence.
Failure to advise on multiple offender rights	State proves predicate convictions and defendant admitted to prior offenses; error harmless.	Failure to advise of rights regarding the multiple offender statute invalidates the adjudication.	Harmless error; documentary proof and defendant’s trial admissions establish predicate offenses; enhancement upheld.

State v. Kirsch, 880 So.2d 890 (La. App. 5th Cir. 2004) (defines unauthorized entry; absence of consent required)
State v. Patterson, 63 So.3d 140 (La. App. 5th Cir. 2011) (employment of standard for sufficiency review)
State v. Rowan, 694 So.2d 1052 (La. App. 5th Cir. 1997) (credibility of witnesses is jury’s function)
State v. Robinson, 874 So.2d 66 (La. 2004) (appellate review of witness credibility limit)
State v. Rivet, 798 So.2d 219 (La. App. 5th Cir. 2001) (standard for appraisal of witness testimony on appeal)
State v. Brown, 82 So.3d 1232 (La. 2012) (harmlessness of rights-advisement error in multiple offender adjudication)
State v. Welch, 615 So.2d 300 (La. 1993) (necessity of context from relationship to evaluate threats)
State v. Cotton, 980 So.2d 34 (La. App. 5th Cir. 2008) (admissibility of other crimes evidence for motive/relationship)
State v. Walker, 394 So.2d 1181 (La. 1981) (prior relationship context for motive admissibility)
State v. Prieur, 277 So.2d 126 (La. 1973) (classic statement of other-crimes admissibility framework)
State v. Anderson, 38 So.3d 953 (La. App. 5 Cir. 2010) (404(B) exceptions and balancing probative value)
State v. Brown, 82 So.3d 1232 (La. 2012) (harmless error when predicate proof exists)