State v. Patin, 150 So. 3d 435

Morris Patin was charged with possession of heroin (28–200g), alprazolam, and oxycodone after JPSO searched a Metairie apartment (consent from lessee Ebonee Williams) and found drugs, packaging, and items linking Patin to the unit. A bail receipt listing Patin and his Hess‑mer address was found in a dresser drawer.
Twenty‑two days earlier NOPD had executed a search warrant at a New Orleans residence where Patin was arrested; officers seized weapons, scales, bagged narcotics, cash, alprazolam tablets, sandwich bags, syringes, and recovered a key found near Patin at the time of arrest.
The State filed a pretrial La. C.E. art. 404(B) notice to admit the New Orleans evidence to show intent/knowledge/absence of mistake; the trial court granted the motion after a 404(B) hearing and gave a limiting instruction to the jury.
At trial much of the New Orleans physical evidence and live testimony from NOPD officers was admitted; defense counsel repeatedly stated “no objection” when exhibits were offered (except for two items: a key—objection overruled—and heroin seized from Patin’s person—sustained).
Patin was convicted on all counts, sentenced (habitual offender adjudication increased Count 1), appealed only one assignment: trial court erred in admitting the New Orleans “other crimes” evidence.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Patin)	Held
Admissibility of New Orleans "other crimes" evidence under La. C.E. art. 404(B)	Evidence was admissible for limited purposes (intent, knowledge, absence of mistake); probative value outweighed prejudice	Evidence was highly prejudicial and effectively introduced other‑crimes as propensity evidence	Admission of the evidence was proper for limited purposes; 404(B) ruling upheld
Failure to contemporaneously object at trial to most New Orleans exhibits	Lack of contemporaneous objection waived appellate review; defense counsel expressly consented when asked	Pretrial objection preserved the issue; trial admission nonetheless erroneous and prejudicial	Most objections were waived; contemporaneous assent precludes appellate review of admission
Whether contemporaneous‑objection rule has a rare‑error exception here	No such extraordinary error occurred (unlike omission of an element or unconstitutional jury instruction)	The volume and nature of other‑crimes evidence so overwhelmed the case that the exception should apply	Exception not applied; normal contemporaneous‑objection rule controls
Harmless‑error and effect on verdict	Any error was not preserved and, where reviewed, probative value supported admission; verdict affirmed	If admission was erroneous, the error was not harmless given overwhelming other‑crimes evidence	Court found no reversible error; convictions and sentences affirmed

Miranda v. Arizona, 384 U.S. 436 (U.S. 1966) (Miranda warnings recited in opinion)
State v. Williamson, 389 So.2d 1328 (La. 1980) (rare exception to contemporaneous‑objection requirement for fundamental jury‑instruction error)
State v. Green, 493 So.2d 588 (La. 1986) (application of Williamson exception to jury instruction defects)
State v. Arvie, 505 So.2d 44 (La. 1987) (contemporaneous objection requirement applied to preserve claims about post‑arrest silence)
State v. Odenbaugh, 82 So.3d 215 (La. 2011) (standards for admitting other‑crimes evidence and harmless‑error review)
State v. Prieur, 277 So.2d 126 (La. 1973) (general rule excluding other‑crimes evidence absent exception)
State v. Jones, 985 So.2d 234 (La. App. 5 Cir. 2008) (other‑crimes evidence admissible to show absence of mistake where defendant blames another)
State v. Lynch, 441 So.2d 732 (La. 1983) (transcript controls over conflicting commitment; remand to correct commitment)