97 So. 3d 522
La. Ct. App.2012Background
- Taylor was charged with possession of a firearm by a convicted felon under LSA-R.S. 14:95.1 after a 2008 bill of information.
- Competency proceedings occurred: initially found competent, then a mistrial granted due to asserted incompetence, followed by a later competency finding of incompetence and then re-evaluation to competency in 2010.
- Trial proceeded in 2011 before a 12-person jury; Miranda rights were at issue during custodial interrogation related to the gun.
- Officer Cannatella testified the gun was found in plain view on the floorboard after a routine traffic stop, with Taylor claiming the gun belonged to a family member.
- The State argued the gun was observed in plain view during a lawful stop and that Taylor’s statement was given after Miranda warnings; the defense argued custodial interrogation and lack of Miranda warnings before the statement.
- Taylor was convicted as charged and sentenced to ten years’ imprisonment, with the sentence to run concurrently with other sentences; post-trial, an appeal was granted.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the motion to suppress the statement was properly denied | Taylor (State) contends Miranda warnings occurred before the statement and the stop was legal; gun obtained via plain view, not via illegality. | Taylor argues custodial interrogation without Miranda warnings tainted the statement and the gun. | No reversible error; denial of suppression affirmed; plain-view gun admissible; any error harmless. |
| Whether Brady material was improperly withheld and whether mistrial was warranted | State argues fingerprints on the bill of information were not usable, but other corroborating records established identity; no material Brady violation. | Taylor claims late disclosure of unusable fingerprints constituted Brady material and warranted mistrial. | No Brady violation; no prejudice; mistrial denied. |
Key Cases Cited
- Horton v. California, 496 U.S. 128 (U.S. 1990) (plain-view doctrine requires immediately apparent contraband with lawful intrusion)
- State v. Hill, 725 So.2d 1283 (La. 1998) (exclusionary rule exceptions: independent source, inevitable discovery, attenuation)
- State v. Armstead, 542 So.2d 28 (La.App. 4th Cir. 1989) (using fingerprints from arrest register to prove identity when not on bill of information)
- State v. Lindsey, 770 So.2d 339 (La. 2000) (identity proof may be established by various competent evidence)
- United States v. Bagley, 473 U.S. 667 (U.S. 1985) (materiality requiring reasonable probability of different outcome if disclosed)