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State v. Thompkins

Citation: 273 So. 3d 346Docket: NO. 2018 KA 1032

Court: Louisiana Court of Appeal; February 27, 2019; Louisiana; State Appellate Court

Narrative Opinion Summary

This case involves the appeal of a defendant convicted of second degree murder and negligent homicide, with concurrent life and five-year sentences, respectively. The defendant sought a new trial and disclosure of a juror's identity, alleging a prejudicial hallway encounter with a juror during the trial. The trial court denied these motions, citing the lack of a contemporaneous objection to the juror encounter and the prior disclosure of juror identities. Additionally, the defendant's argument that his incarceration served as an alibi was refuted by evidence including recorded phone calls. The court affirmed the conviction, emphasizing the waiver of the right to appeal due to the absence of timely objections. Claims of insufficient evidence were rejected, and the court held that the defendant failed to demonstrate fundamental errors warranting review without a contemporaneous objection. Consequently, the defendant's convictions and sentences were upheld, maintaining the trial court's procedural and evidentiary rulings.

Legal Issues Addressed

Disclosure of Juror Identity

Application: The trial court found no merit in the defendant's claim for disclosure of a juror's identity because juror identities were already disclosed at trial, and no objection was made contemporaneously.

Reasoning: The state countered that juror identities were disclosed at trial and that the juror could have been identified if an objection had been made.

Insufficient Evidence Claim

Application: The defendant's claim of insufficient evidence was rejected, as the trial court upheld the conviction based on the evidence presented, including recorded phone calls.

Reasoning: The court affirmed the defendant's convictions and life sentence for drug-related offenses, rejecting claims of insufficient evidence.

Preservation of Errors for Appeal

Application: The court emphasized that failure to object contemporaneously to trial errors results in a waiver of the right to appeal those issues.

Reasoning: The court emphasized that under Louisiana law, a failure to object contemporaneously waives the right to raise the issue on appeal.

Review of Fundamental Errors Without Contemporaneous Objection

Application: The court ruled that the defendant did not meet the standard for invoking exceptions to the contemporaneous objection rule for fundamental errors.

Reasoning: Errors affecting fundamental rights can be reviewed on appeal without a contemporaneous objection, but the defendant did not meet the necessary standard to invoke this exception.

Standard for Granting a New Trial

Application: The defendant's motion for a new trial was denied due to the lack of a timely objection regarding the alleged juror encounter during the trial.

Reasoning: The trial court denied both motions, noting the lack of contemporaneous objection regarding the hallway encounter and stating that the jury was already aware of Thompkins' incarceration due to the nature of the trial.