State v. Breaux
2010 La. App. LEXIS 1506
| La. Ct. App. | 2010Background
- Defendant Breaux was charged by grand jury indictment with armed robbery and conspiracy to commit armed robbery.
- After a jury trial, Breaux was convicted as charged and adjudicated a fourth-felony offender.
- Sentences: life imprisonment without probation, parole, or suspension, on both counts, to be served concurrently.
- The offenses involved a fatal April 19, 2008 robbery of Uchenna Ezike, whose death was later attributed to a skull fracture, not the car crash scene.
- Police linked the crime to Hardy and Gipson, who later admitted Breaux's involvement and recounted the plan and execution.
- Hardy used Ezike’s card data at Circle K; Gipson also used Ezike’s cards; two accomplices pled guilty later.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the trial court correctly handled the Batson/ reverse-Batson issue | Breaux claims state failed to prove race-based challenges | Breaux argues state bore burden to show race-neutral reasons | Court found proper Batson three-step analysis; no reversible error on reverse-Batson as to most challenges |
| Whether denial of secret-ballot paper slips affected fair deliberations | Breaux asserts denial tainted deliberations | Court lacked basis to require secret ballots | denial of slips did not taint deliberations; no merit to this assignment |
Key Cases Cited
- Batson v. Kentucky, 476 U.S. 79 (1986) (prohibits peremptory challenges based on race)
- Georgia v. McCollum, 505 U.S. 42 (1992) (reverse-Batson principle against racially discriminatory defense strategies)
- State v. Draughn, 950 So.2d 583 (La. 2007) (three-step Batson analysis in Louisiana context)
- State v. Givens, 776 So.2d 443 (La. 2001) (prima facie Batson showing framework)
- Price v. Cain, 560 F.3d 284 (5th Cir. 2009) (light burden to establish prima facie Batson case)
- Johnson v. California, 545 U.S. 162 (2005) (purposeful discrimination burden on opponent of the strike)
- Hernandez v. New York, 500 U.S. 352 (1991) (deference to trial judge's discriminatory-intent determinations)
- Juniors v. State, 915 So.2d 291 (La. 2005) (deference to voir dire demeanor in discrimination determinations)
- Mitchum v. State, N/A (La.) (discussed in Batson context (mentioned in record))