State v. Williams
2003 WL 1477659, 842 So. 2d 1143 (2003)
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Rule of Law:
A conviction for second-degree kidnapping under La. R.S. 14:44.1(B)(1) requires proof of the victim's relocation from one physical setting or environment to another, not merely movement within the same immediate location. However, a conviction may be upheld under a different statutory subsection if the evidence presented at trial supported it and the defendant was not misled or prejudiced by an incorrectly alleged subsection in the bill of information.
Facts:
- On August 15, 2000, Lilly Riley called her husband, Reginald Williams, to pick her up from her mother's house.
- Williams, initially reluctant, later arrived at Riley's mother's house and promised Riley's mother that he would not harm Riley and that they would resolve their marital issues.
- Riley left with Williams, and upon arriving at their home, Williams threatened Riley, stating he would "knock your ass off" if she tried to run.
- Riley attempted to flee by running outside, but Williams chased her, grabbed a shovel, blocked her path, and threatened to hit her with it if she did not re-enter the house.
- Once inside, Williams latched and chained the door, then forcibly removed Riley's hands from the door handle, threw her to the floor, sat on her back, and beat her head, stating he would kill her.
- During the struggle, Riley broke a glass table with her foot.
- After Williams became tired, Riley went upstairs, discovered the phone disconnected, and jumped out a window, sustaining a broken foot and other injuries.
- Outside, Riley called for children to summon the police, but Williams came out, pushed her down, and taunted her before driving away, leaving Riley to be helped by a neighbor and later taken to the hospital.
Procedural Posture:
- Reginald Williams was charged by bill of information on November 6, 2000, with second degree kidnapping in violation of La. R.S. 14:44.1.
- Williams pled not guilty at arraignment.
- A preliminary hearing was held on December 18, 2000, and the trial court found probable cause.
- The State filed a notice of intent to introduce evidence of other crimes by Williams.
- A Prieur hearing on the State's motion was conducted on January 22, 2001, and the trial court granted the State's motion on March 9, 2001.
- On April 24, 2001, Williams selected trial by judge.
- The trial court found Williams guilty as charged.
- Williams filed a motion for new trial, which the trial court denied on June 6, 2001.
- Williams was sentenced to five years in the custody of the department of corrections, with the first two years to be served without benefit of probation, parole or suspension of sentence.
- The State filed a multiple offender bill of information, alleging Williams to be a second felony offender.
- On November 9, 2001, the trial court found Williams to be a second felony offender and sentenced him to twenty years at hard labor in the custody of the Department of Corrections, with the first two years to be served without benefit of probation, parole or suspension of sentence.
- Williams filed a motion to reconsider sentence, which the trial court denied on November 20, 2001.
- Williams filed a motion for appeal, which was granted.
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Issue:
Does evidence showing a defendant forced a victim from immediately outside a house back inside, followed by an assault, satisfy the "forcible seizing and carrying of any person from one place to another" element of second-degree kidnapping under La. R.S. 14:44.1(B)(1), or can a conviction be upheld under a different subsection of the statute if the evidence supports it and the defendant was not misled by the initial charging document?
Opinions:
Majority - Joan Bernard Armstrong
No, the evidence did not establish the "forcible seizing and carrying from one place to another" element of second-degree kidnapping as charged in the bill of information under La. R.S. 14:44.1(B)(1). However, yes, the conviction can be upheld because the evidence was sufficient to support a conviction under other applicable subsections of the second-degree kidnapping statute (La. R.S. 14:44.1 A(3) or A(5) with B(3)), and the defendant was not misled regarding the evidence the State intended to present. The court referenced State v. Davillier and State v. Bowie, which held that "from one place to another" requires a relocation from one physical setting or environment to another, and that movement from outside a door to inside the door, or within the same structure, is insufficient. Therefore, Williams forcing Riley from just outside their house back inside did not meet the B(1) element. However, the court found the evidence was sufficient to support a conviction under subsections A(3) (victim physically injured) or A(5) (offender armed with a dangerous weapon) combined with B(3) (imprisoning or forcible secreting of any person), as Williams forcibly detained Riley, threatened her with a shovel, and beat her, causing injury. Citing State v. Wright, State v. Ruffin, and State v. Schrader, the court reasoned that a conviction could be upheld where the evidence supported a different subsection of the statute than that alleged in the bill of information, provided the defendant was not misled. The court noted that defense counsel was present at a suppression hearing where the victim's testimony included the facts supporting B(3) and that counsel's statements at trial indicated an awareness that the State's evidence related to subsections A(3)/A(5) with B(3), demonstrating that counsel was not unprepared or surprised by the evidence presented.
Analysis:
This case provides crucial clarification on the "from one place to another" element of second-degree kidnapping under Louisiana law, establishing a higher threshold for movement than mere repositioning within an immediate vicinity. More broadly, it reinforces the principle that procedural technicalities in charging documents, such as citing an incorrect statutory subsection, will not automatically invalidate a conviction if the defendant had actual notice of the facts forming the basis of the charge and was not prejudiced in preparing a defense. This decision balances the prosecution's duty to accurately charge with the court's role in upholding convictions based on sufficient evidence, thereby preventing reversals on purely formal grounds when substantive due process has been afforded.
