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State v. Santacruz

Citations: 392 So. 2d 380; 1980 La. LEXIS 8332Docket: No. 66539

Court: Supreme Court of Louisiana; September 12, 1980; Louisiana; State Supreme Court

Narrative Opinion Summary

Taylor v. Louisiana, 419 U.S. 522 (1975), which addresses the jury selection process, is determined not to apply retroactively to convictions rendered by juries empaneled before January 21, 1975. The court references additional cases, including Daniel v. Louisiana, State v. Rester, State v. Watkins, State v. Simmons, and State v. King, to support this conclusion. The defendant in the current case was tried and convicted on March 7, 1974, prior to the Taylor decision. Consequently, the application for rehearing is denied. The lower court's decision is noted as La. 386 So.2d 364.

Legal Issues Addressed

Application of Precedent in Jury Selection

Application: The court referenced multiple prior cases to support the conclusion that the Taylor decision does not apply retroactively, thereby affirming the conviction of a defendant tried before the decision was made.

Reasoning: The court references additional cases, including Daniel v. Louisiana, State v. Rester, State v. Watkins, State v. Simmons, and State v. King, to support this conclusion.

Denial of Rehearing Based on Existing Precedent

Application: The application for rehearing by the defendant, who was convicted before the Taylor decision, is denied based on the established non-retroactivity of the decision.

Reasoning: The defendant in the current case was tried and convicted on March 7, 1974, prior to the Taylor decision. Consequently, the application for rehearing is denied.

Non-retroactivity of Judicial Decisions

Application: The principle established in Taylor v. Louisiana regarding jury selection does not apply to cases with convictions rendered by juries empaneled before the decision date of January 21, 1975.

Reasoning: Taylor v. Louisiana, 419 U.S. 522 (1975), which addresses the jury selection process, is determined not to apply retroactively to convictions rendered by juries empaneled before January 21, 1975.