State v. Langley
61 So. 3d 747
La. Ct. App.2011Background
- Louisiana v. Langley involves the 1992 murder of Jeremy Guillory and Langley’s confession to police after being arrested on a Georgia parole warrant.
- Jeremy’s body was found in Langley’s rented bedroom, with a ligature and sock in place, and semen found on a shirt seam later linked to Langley by DNA.
- Langley was tried multiple times: capital murder in 1994 (death sentence), retried for first-degree murder later, and finally convicted of second-degree murder in 2009 after lengthy pretrial proceedings.
- The first two trials were overturned due to judicial error (inactive trial judge; structural defects) and a prior reversal by the Louisiana Supreme Court, leading to retrials and legal wrangling over double jeopardy and the law of the case.
- Langley appeals on ten substantive assignments of error, including double jeopardy, speedy trial, suppression of statements, admissibility of prior records, and the recusal of a judge.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Double jeopardy and collateral estoppel in retrial | Langley argues retrial for specific intent murder violated double jeopardy | Langley contends issue of specific intent was decided against him in the first trial | No error; retrial permissible after judicial error; collateral estoppel not satisfied |
| Whether the retrial/vexing pretrial history violated prescription | Langley asserts prescription barred retrial | State contends tolling due to pending motions and recusal | Trial timely; prescription tolled by pending motions and unresolved recusal; speedy-trial rights not violated |
| Constitutional speedy-trial rights given long delay | Langley claims 17-year gap violated Barker factors | Delay due to complex procedural history; defendant delayed filing motions | Delay justified by unique procedural history; Barker factors not met for violation |
| Reliability/relevance of confessions and expert testimony | Langley sought to present psychologist to counter confession validity | Fulero testimony not helpful; Delouche interrogation background irrelevant | Court did not abuse discretion; Daubert considerations moot; cross-examination of Delouche limited but not improper |
| Admissibility of Georgia records and | Langley argues Georgia records should be excluded as law-of-the-case | State contends law-of-the-case does not bar admissibility; records relevant to issues | Law-of-the-case doctrine not applicable; records admissible under proper relevance; diary referenced fairly |
| Admissibility of the March 26, 1992 statement | Langley argues March 26, 1992 confession should be suppressed | Motion not properly preserved; earlier ruling affirmed | Issue not properly preserved on appeal; prior ruling stands; statement admissible |
| Authority to arrest under La. Code Crim.P. Art. 213(4) | Georgia parole warrant could justify Louisiana arrest for parole violation | Dispute over whether parole violation warrant qualifies as felony warrant | Art. 213(4) includes parole warrants; arrest proper; suppression not warranted |
| Law-of-the-case effect on admission of Georgia records/dream diary | Law-of-the-case barred prior rulings on these records | Law-of-the-case does not bar admissibility in bench trial; prejudice not preserved | Law-of-the-case not controlling; records admissible; prejudice not shown |
| Recusal of judge Carter | State seeks recusal due to potential bias | Langley challenges recusal standard | Recusal warranted; case remanded for proceedings before a different judge |
Key Cases Cited
- Ashe v. Swenson, 397 U.S. 436 (U.S. 1970) (collateral estoppel limits relitigation of ultimate facts)
- State v. Ingram, 885 So.2d 714 (La. App. 5th Cir. 2004) (collateral estoppel—facts necessarily determined)
- Langley, State v. Langley, 896 So.2d 200 (La. App. 3 Cir. 2004) (structural errors; nullity; prior reversals)
- Langley, State v. Langley, 711 So.2d 651 (La. 1998) (grand jury discrimination; remand for evidentiary hearing)
- Langley, State v. Langley, 958 So.2d 1160 (La. 2007) (Langley III; Supreme Court remanded on retrial viability)
- State v. Manning, 885 So.2d 1044 (La. 2004) (Daubert framework for expert testimony)
- State v. Shaw, 969 So.2d 1233 (La. 2007) (statutory interpretation of Article 213(4))
- State v. Alfred, 337 So.2d 1049 (La. 1976) (Barker speedy-trial factors application)
- State v. Legrand, 864 So.2d 89 (La. 2003) (closing argument standards; prosecutorial latitude)
- United States v. Leon, 468 U.S. 897 (U.S. 1984) (good faith exception to the exclusionary rule)
- State v. Graham, 375 So.2d 374 (La. 1979) (law-of-the-case does not bar new trial evidence)
- State v. Barrett, 408 So.2d 903 (La. 1981) (parole violation arrest authority)