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State v. Ball

Supreme Court of Louisiana
1999 WL 1077084, 756 So. 2d 275 (1999)
ELI5:

Rule of Law:

In a prosecution for possession of a firearm by a convicted felon under a state statute that enumerates specific predicate felonies, the state is not required to accept a defendant's offer to stipulate to their prior felon status. The state may introduce evidence of the name and nature of the prior conviction as proof of an essential element of the crime.


Facts:

  • In 1993, Ricko C. Ball pleaded guilty to the felony of simple burglary of an inhabited dwelling.
  • On November 4, 1996, Mary Upton's minivan was stolen from her driveway after her son's truck, parked in front of it, was broken into.
  • The keys to the minivan, a shotgun, and a rifle were stolen from the son's truck.
  • A few hours later, police spotted Ball driving the stolen minivan.
  • Ball led police on a high-speed chase, which ended when he crashed the minivan into a ditch and fled on foot.
  • Police apprehended Ball shortly after he fled the vehicle.
  • Inside the minivan, police found the stolen rifle and shotgun in plain view on the floorboard.
  • Ball's fingerprints were found on the window of the son's truck from which the items were stolen.

Procedural Posture:

  • The State of Louisiana charged Ricko C. Ball in the Caddo Parish trial court with possession of a firearm by a convicted felon.
  • Before trial, Ball filed a Motion in Limine to preclude the state from introducing the name and nature of his prior felony, offering instead to stipulate to his status as a convicted felon.
  • The trial court denied the motion.
  • At trial, the state introduced documentary evidence of Ball's prior conviction for simple burglary of an inhabited dwelling.
  • A jury found Ball guilty as charged, and the trial court sentenced him to 13 years at hard labor and a $1,000 fine.
  • Ball (appellant) appealed to the Court of Appeal, Second Circuit, which affirmed his conviction and sentence.
  • Ball (applicant) then successfully sought a writ of certiorari from the Supreme Court of Louisiana to review the lower courts' decisions.

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Issue:

In a prosecution for being a felon in possession of a firearm under La. R.S. 14:95.1, is it a reversible error for a trial court to permit the state to introduce evidence of the name and nature of the defendant's prior felony conviction when the defendant has offered to stipulate to his status as a convicted felon?


Opinions:

Majority - Victory, J.

No. It is not a reversible error for a trial court to permit the state to introduce evidence of the name and nature of the defendant's prior felony conviction when the defendant has offered to stipulate to his status as a convicted felon. The U.S. Supreme Court's decision in Old Chief v. United States is not controlling because it interpreted a federal statute that criminalizes firearm possession for those convicted of any generic felony, whereas the Louisiana statute, La. R.S. 14:95.1, lists specific, enumerated felonies as predicate offenses. Because the specific nature of the prior conviction is an essential element of the crime under Louisiana law, its probative value is high and is not substantially outweighed by the risk of unfair prejudice. Furthermore, the prosecution is entitled to prove its case with evidence of its own choice and cannot be forced to accept a stipulation that would diminish the evidentiary force of its presentation.


Concurring - Lemmon and Johnson, JJ.

Justices Lemmon and Johnson concurred without a written opinion.



Analysis:

This decision carves out a significant exception to the federal rule established in Old Chief v. United States, distinguishing Louisiana's 'specific-felony' statute from the 'generic-felony' federal statute. By doing so, the Louisiana Supreme Court affirmed the state's broad discretion to prove every element of an offense with its chosen evidence, prioritizing the state's narrative power over concerns of potential jury prejudice. The ruling establishes a precedent in Louisiana that the name and nature of a prior conviction are admissible when the statute requires a specific predicate offense, thereby limiting defendants' ability to sanitize their record before a jury in such cases. This places Louisiana in a category of states that reject the Old Chief rationale based on the specific wording of their respective statutes.

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