State v. Granger, 103 So. 3d 576

Granger was charged with aggravated burglary under La. Rev. Stat. 14:60 and forcible rape under La. Rev. Stat. 14:42.1; he pled not guilty.
Competency hearings began in 2009; he was found incompetent and confined, then eventually found competent after a third hearing in 2011.
State filed a Notice of Intent to Use Evidence of Other Crimes; the trial court granted the notice on August 15, 2011.
On August 17, 2011 a 12-person jury found Granger guilty on both counts; he was sentenced to 80 years’ hard labor to be served concurrently, with two years on count two without parole.
The State introduced multiple prior acts of stalking/domestic abuse as 404(B) evidence; the defense challenged sufficiency and admissibility; appellate review also addressed an error-patent issue regarding sex-offender registration notification.
The record shows the victim, a Trinidad native, had a lengthy history of abuse and stalking by Granger, including incidents in 2004–2009, police reports, 911 calls, and physical and sexual assaults culminating in the March 6–7, 2009 offenses.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of the evidence for forcible rape and aggravated burglary	State contends testimony plus physical evidence established elements.	Defense points to inconsistencies and argues credibility issues.	Sufficient evidence supported both convictions; jury credibility determinations upheld.
Admissibility of other crimes evidence under Article 404(B)	Evidence of prior stalking/abuse relevant to motive/relationship; not offered to show bad character.	Highly prejudicial; not necessary to prove elements; risk of improper propensity inference.	Court did not abuse discretion; probative value outweighed prejudice; limiting instruction given.
Error patent: sex-offender registration notification and related advisement	Statutory notification required; failure to notify constitutes error patent.	Not contested as to failure; any delay is subject to ordinary remedial procedures.	Conviction affirmed; remanded for proper sex-offender registration notification.
Post-conviction/appeal procedure and claimed discovery issue			Defendant’s discovery-related claim deemed abandoned or inadequately briefed; no relief granted.

State v. Rose, 949 So.2d 1236 (La. 2007) (motive/relationship evidence admissible under 404(B))
State v. Prieur, 277 So.2d 126 (La. 1973) (procedural prerequisites for admitting prior acts (Prieur notice))
State v. Noil, 807 So.2d 295 (La. App. 5th Cir. 2001) (standard for reviewing 404(B) rulings; abuse of discretion)
State v. Page, 28 So.3d 442 (La. App. 5 Cir. 2009) (Prieur notice requirements and 404(B) analysis)
State v. Jackson, 926 So.2d 72 (La. App. 5 Cir. 2006) (prejudice/whether 404(B) evidence prejudices substantial rights)
State v. Welch, 615 So.2d 300 (La. 1993) (admissibility of threats/acts to show volatile relationship)
State v. Cotton, 980 So.2d 34 (La. App. 5 Cir. 2008) (similar 404(B) analysis showing motive/relationship context)
State v. Adams, 89 So.3d 435 (La. App. 5 Cir. 2012) (admission of other crimes evidence for motive/entering an apartment)
State v. Vessell, 450 So.2d 938 (La. 1984) (credibility determinations defer to jury)
State v. Robinson, 874 So.2d 66 (La. 2004) (standard for sufficiency post-Gray/ Jackson framework)
Jackson v. Virginia, 443 U.S. 307 (1980) (sufficiency review standard)