128 So. 3d 370
La. Ct. App.2013Background
- Allen Snyder was originally convicted of first-degree murder in 1996 and sentenced to death; after multiple appeals and U.S. Supreme Court remands (including Snyder v. Louisiana), he was re-indicted for second-degree murder in 2009 and tried in 2012.
- The underlying incident (Aug. 16, 1995): Snyder approached a car containing his estranged wife Mary Beth and Howard Wilson, a fight occurred, Wilson sustained fatal sharp-force injuries and Mary Beth was severely stabbed but survived.
- Physical and forensic evidence: Snyder gave a post-arrest statement admitting he confronted them with a knife; a white T-shirt found hidden in his attic tested positive for blood consistent with Wilson’s DNA; the murder weapon was never recovered.
- The State admitted evidence of multiple prior domestic incidents between Snyder and Mary Beth (Prieur/404(B) evidence) to show motive, intent, preparation, and plan.
- At trial the jury convicted Snyder of second-degree murder; he was sentenced to life imprisonment without parole; Snyder appealed raising three evidentiary/mistrial claims.
Issues
| Issue | Plaintiff's Argument (State) | Defendant's Argument (Snyder) | Held |
|---|---|---|---|
| Motion for mistrial after jury briefly saw Miranda/advice-of-rights form indicating a "First Degree Murder" charge | The exposure was inadvertent, brief, and not shown to have prejudiced jurors; objection timing not specific so issue not preserved | The reference to first-degree murder was prejudicial and warranted a mistrial | Not preserved under contemporaneous-objection rule; even if considered, denial of mistrial was not an abuse of discretion because glimpse was brief and not shown to cause substantial prejudice |
| Admission of other-crimes/domestic-violence evidence under La. C.E. art. 404(B) / Prieur | Evidence was relevant to motive, intent, preparation/plan and probative value outweighed prejudice; previously litigated and upheld | Prior domestic acts unfairly portrayed Snyder as a violent character and likely converted a potential manslaughter case into second-degree murder | Court applied law-of-the-case to prior appeal and found no abuse of discretion; Prieur evidence admissible for motive/intent and probative value outweighed prejudice |
| Court-ordered disclosure of Mary Beth’s letters and limitation on cross-examination | Prosecution sought inspection because letters bore on her state of mind and the State was entitled to meaningful redirect; discovery rules apply | Forcing disclosure and cutting off questions infringed defendant’s confrontation/right to present a defense and chilled cross-examination | Issue not preserved in the form argued on appeal; defendant declined to proffer excluded questioning and thus failed to preserve a substantial-rights claim; no reviewable error shown |
Key Cases Cited
- Batson v. Kentucky, 476 U.S. 79 (prohibiting race-based peremptory strikes)
- Miller-El v. Dretke, 545 U.S. 231 (clarifying evidence standards for Batson claims)
- Snyder v. Louisiana, 552 U.S. 472 (trial judge erred in Batson analysis; led to remand)
- Huddleston v. U.S., 485 U.S. 681 (preponderance standard for proving extrinsic-act evidence admissibility)
- Miranda v. Arizona, 384 U.S. 436 (Miranda warnings and waiver requirements)
- State v. Prieur, 277 So.2d 126 (La. 1973) (procedures and limits for admitting other-crimes evidence under La. law)