State v. Grant, 105 So. 3d 81

Grant was convicted by jury of attempted second degree murder and adjudicated a fourth-felony offender, receiving life without parole.
The offense occurred October 5, 2008, when three gunmen in an SUV opened fire on three domino players, wounding Michael Parker and injuring none of the other two victims.
Pursuit followed; officers observed three black males firing from the SUV; the vehicle stopped, suspects fled, and weapons were recovered from two houses during a protective sweep.
Hall and Ross were charged and tried separately; Grant’s conviction and life sentence were affirmed after habitual-offender sentencing.
On appeal, Grant raises Batson challenges, claims about post-arrest silence (Doyle issue), ineffective assistance, and the need for an accomplice-testimony cautionary instruction.
The appellate court affirms Grant’s conviction and sentence, addressing each issue and finding no reversible error.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Batson challenge sufficiency	Grant asserts the state struck African-American jurors on race.	Grant contends the State failed to show race-neutral explanations for several strikes.	Court affirms denial of Batson challenges; explanations credible and no purposeful discrimination.
Comment on defendant's silence (Doyle issue)	State impermissibly referenced post-arrest silence after Miranda warnings.	Counsel ineffective for failing to object to the Doyle error.	Doyle violation found harmless; references did not prejudice trial; no ineffective-assistance finding.
Ineffective assistance of counsel	Defense counsel failed to object to numerous trial violations; prejudice presumed.	Counsel's performance deficient and prejudicial; ineffective assistance.	No reversible deficiency shown; Strickland standard not met; no prejudice demonstrated.
Accomplice testimony jury instruction	Defense failed to request cautionary instruction on Hall's testimony.	Instruction needed to safeguard credibility of accomplice testimony.	No error; record shows sufficient corroboration and testimony instructions; no ineffective-assistance finding.

Batson v. Kentucky, 476 U.S. 79 (U.S. 1986) (peremptory challenges based on race violate Equal Protection)
Rice v. Collins, 546 U.S. 333 (U.S. 2006) (three-step Batson framework for disproportional strikes)
State v. Anderson, 996 So.2d 973 (La. 2008) (trial court deference for Batson credibility findings)
State v. Hughes, 943 So.2d 1047 (La. 2006) (accomplice testimony admissibility and corroboration standards)
State v. Castleberry, 758 So.2d 749 (La. 1999) (accomplice testimony credibility and corroboration guidance)
State v. McClain, 222 So.2d 855 (La. 1969) (silence as substantive evidence in proper circumstances)
State v. Carey, 628 So.2d 27 (La. App. 2d Cir. 1993) (prearrest silence and admissibility considerations)
Doyle v. Ohio, 426 U.S. 610 (U.S. 1976) (federal rule prohibiting post-arrest silence used for impeachment)
Jenkins v. Anderson, 447 U.S. 231 (U.S. 1980) (pre-arrest silence may be used to impeach on cross-examination)
Langston v. State, 3 So.3d 707 (La. App. 2d Cir. 2009) (harmless error standard for Doyle violations)