State v. Jenkins, 267 So. 3d 203

Defendant Ronji Jenkins, Jr. was charged with obscenity for allegedly exposing and masturbating in front of Officer Yashonda Lee at Jefferson Parish Correctional Center on October 27, 2016.\
Officer Lee testified she observed defendant standing between his toilet and bunk, staring at her while stroking his penis despite her gestures to stop; defendant testified he was urinating and briefly shook himself before dressing.\
Jury convicted defendant on January 3, 2018; initial sentence of three years hard labor was vacated after a multiple-offender hearing and replaced with a six-year DOC sentence without benefits on March 8, 2018.\
Prior to trial the State gave notice under La. C.E. art. 404(B) of intent to introduce defendant’s 2008 conviction for battery of a correctional facility employee (involving spit/assault on an officer) to prove intent/absence of mistake.\
Trial court admitted the 2008 conviction over defense objection; a limiting instruction was later given to the jury. On appeal the admission was challenged as unduly prejudicial and not probative of obscenity intent.\
Appellate court found admission of the 2008 conviction was an abuse of discretion but harmless because Officer Lee’s testimony alone was sufficient to support the obscenity conviction; court affirmed conviction and remanded to correct dates on the uniform commitment order.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admissibility of other-crimes evidence (2008 battery conviction)	The 2008 conviction shows defendant's lack of respect for correctional officers and is admissible to prove intent, absence of mistake, and guilty knowledge under La. C.E. art. 404(B).	The 2008 conviction occurred when defendant was 17, is factually unrelated, non-sexual, remote in time, highly prejudicial, and does not show intent to commit obscenity.	Trial court abused discretion admitting the prior conviction (not relevant to sexual intent), but error was harmless because State presented sufficient evidence (victim testimony) without it.
Errors patent / sentencing documentation	N/A (prosecution did not dispute clerical correction)	Trial court’s uniform commitment order contained incorrect dates for disposition, vacation of original sentence, and multiple-offender sentencing.	Court remanded to correct the uniform commitment order dates and to transmit corrected order per procedure.

State v. Prieur, 277 So.2d 126 (La. 1973) (standard limiting admissibility of other crimes evidence)\
State v. Garcie, 242 So.3d 1279 (La. App. 5 Cir.) (other crimes admissibility discussion)\
State v. Lawson, 1 So.3d 516 (La. App. 5 Cir.) (other crimes exceptions and relevance)\
State v. Maize, 223 So.3d 633 (La. App. 5 Cir.) (review of trial court discretion on 404(B) rulings)\
State v. Williams, 921 So.2d 1033 (La. App. 5 Cir.) (harmless error standard: verdict surely unattributable to error)\
State v. Brown, 901 So.2d 492 (La. App. 5 Cir.) (victim testimony alone can support conviction)\
State v. Higgins, 898 So.2d 1219 (La. 2005) (one witness’s credible testimony sufficient absent contradiction)\
State v. Oliveaux, 312 So.2d 337 (La. 1975) (requirement to review record for errors patent)\
State v. Weiland, 556 So.2d 175 (La. App. 5 Cir.) (errors patent jurisprudence)\
State v. Long, 106 So.3d 1136 (La. App. 5 Cir.) (procedure for correcting and transmitting uniform commitment orders)