State v. Robinson
246 So. 3d 725
La. Ct. App.2018Background
- Defendant Steven D. Robinson (born 1964) was tried by jury and convicted of two counts of molestation of a juvenile under La. R.S. 14:81.2: one count involving Y.S. (born 1999) occurring in 2015, and one involving L.A. (born 1998) occurring in 2011.
- Y.S. (age 15–16 during incidents) testified Robinson repeatedly forced sexual intercourse on her after she called him for rides; she did not report immediately because she feared him. L.A. (age 12 at incident) testified Robinson kissed her neck and touched her genitals through clothing in a bedroom.
- The State introduced testimony from three other women (A.F., T.F., J.W.) describing prior sexually assaultive acts by Robinson spanning the 1980s–2001; the trial court admitted that evidence under La. C.E. art. 412.2 as showing a lustful disposition toward children.
- Robinson testified and denied the sexual contacts; the jury convicted him on both counts. Sentences: 7 years hard labor (Count One) and 50 years hard labor with first 25 years without benefits (Count Two), to run consecutively; fines and costs also imposed.
- On appeal Robinson challenged (1) sufficiency of the evidence and (2) admission of other-crimes/acts evidence. The appellate court affirmed convictions and sentences.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of evidence for Count One (Y.S.) | Testimony established lewd acts, force and control; victim testimony alone suffices | State failed to prove force, control, or elements beyond reasonable doubt | Affirmed: viewing evidence in light most favorable to prosecution a rational juror could find guilt beyond reasonable doubt (victim testimony sufficient) |
| Sufficiency of evidence for Count Two (L.A.) | Testimony showed lewd touching by older relative exercising influence/control | Conduct was not lewd/lascivious or lacked requisite force/control | Affirmed: jurors reasonably found lewd acts and influence by position of control over a 12‑year‑old |
| Admission of other-crimes/acts evidence (La. C.E. art. 412.2) | Evidence showed pattern/lustful disposition relevant to charged offenses | Evidence was prejudicial, dissimilar, and should have been excluded; preservation argued but not made at trial | Affirmed: evidence was admissible under art. 412.2; similar sexually assaultive acts probative of lustful disposition; trial court did not abuse discretion; defendant failed to contemporaneously preserve objection |
| Sentence/excessiveness challenge | (Implicit) Sentence disproportionate | Sentence excessive/unconstitutional | Affirmed: appellate court rejected argument and upheld sentences (no reversible error noted) |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (1979) (standard for sufficiency review: whether any rational trier of fact could find guilt beyond reasonable doubt)
- State v. Hearold, 603 So.2d 731 (La. 1992) (appellate sufficiency review and interplay with trial error issues)
- State v. Watson, 743 So.2d 239 (La. App. 2 Cir. 1999) (victim testimony alone can suffice in sexual‑assault cases)
- State v. Casey, 775 So.2d 1022 (La. 2000) (trial court credibility determinations entitled to deference)