54 So. 3d 1129
La. Ct. App.2010Background
- Williams, Green, and Maynor were convicted after a joint trial of armed robbery and false imprisonment with a dangerous weapon at Norris’s rural Caldwell Parish home.
- Norris allowed Johnson to stay at his home while he worked overseas; on Dec 14, 2008, three robbers broke in, held Johnson and Anders at gunpoint, and were arrested at the scene.
- Evidence showed Williams and Green used a handgun, removed Johnson’s weapon, and Maynor held others at gunpoint during the burglary.
- The jury convicted all three defendants on all counts; appellate issues followed.
- Court reversed false imprisonment convictions for Williams, Green, and Maynor due to double jeopardy, affirmed other convictions, and amended sentences as discussed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of the evidence | Williams/Green: insufficient evidence; credibility of Johnson and deputy Morris attacked | Williams/Green: identity and value taken not proven | Evidence sufficient to convict Williams and Green of both crimes. |
| Double jeopardy with armed robbery and false imprisonment | Prosecutions punished twice for same conduct | Convictions separate offenses under Blockburger; same-evidence test applied | False imprisonment convictions reversed; armed robbery sustained—double jeopardy violation persists for the lesser offense. |
| Batson challenge and juror Tatum | Prosecution used peremptory strike against Tatum with racial motivation | Race-neutral reasons later provided; initial reseating proper | No Batson error; reasons race-neutral; no reversible error. |
| Mistrial rulings | Denial of mistrial on two occasions prejudicial | Admonitions and Article 771 cure; no abuse of discretion | Denials of mistrial upheld; admonitions adequate. |
| Consolidation and handling of Anders case | Consolidation improper without objection; prejudice must be shown | Trial court’s consolidation did not prejudice defendants | Consolidation affirmed; no prejudice shown. |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (U.S. 1979) (sufficiency of evidence standard for due process check)
- State v. Henson, 882 So.2d 670 (La.App.2d Cir. 2004) (credibility and appellate deference to jury witness credibility)
- State v. Steele, 387 So.2d 1175 (La.1980) (double jeopardy same-evidence test guidance)
- State v. Robertson, 511 So.2d 1237 (La.App.2d Cir.1987) (same evidence test application to dual offenses)
- State v. Ceasar, 856 So.2d 236 (La.App.2d Cir.2003) (Blockburger test and same-offense considerations)
- Batson v. Kentucky, 476 U.S. 79 (U.S. 1986) (prohibition on race-based peremptory strikes)