Full title: STATE OF LOUISIANA v. ISAIAH DOYLE
Court: Court of Appeals of Louisiana, Fifth Circuit
Date published: Dec 22, 2021
Facts
On November 5, 2005, a grand jury in Jefferson Parish returned a true bill of indictment that charged the defendant, Isaiah Doyle, with one count of first degree murder, in violation of La. R.S. 14:30. On March 8, 2006, the defendant was found incompetent to stand trial and he was remanded to the Eastern Louisiana Mental Health System-Forensic Division on June 7, 2007. Co-defendant, Jose Rojas, filed motions to suppress confession, evidence, and identification in case number 05-5961, on May 4, 2007, that were later adopted by defendant. On March 19, 2008, following a hearing, the defendant was found competent to stand trial by the district court.
On June 5 and July 31, 2009, suppression hearings were held but left open. On August 24, 2009, a suppression hearing was held, after which the trial court denied defendant’s motion to suppress statements. On December 14, 2009, the trial court granted the defendant’s motion to represent himself and, on that same date, he withdrew a plea of not guilty and entered pleas of not guilty by reason of insanity. On December 17, 2009, the defendant was held in contempt of court and sentenced to six months in parish prison. Afterwards, on that same date, the trial court ordered the Louisiana Capital Conflict Panel to represent the defendant, and on January 13, 2010, the trial court ordered the Baton Rouge Capital Conflict Office to represent him as well.
On March 11, 2011, defense counsel filed a motion for psychiatric evaluation which asserted that, as the trial approached, the defendant’s “mental condition is deteriorating to the point where he is not able to assist counsel.” On March 14, 2011, while the defendant was represented by counsel, the district court commenced a competency hearing. At the conclusion of the hearing, the defendant was found competent to stand trial. Jury selection began on that same date. At an arraignment on March 19, 2011, the defendant pled not guilty and not guilty by reason of insanity. On March 21, 2011, the defendant filed a Motion to Quash the Venire that was denied.
On March 21, 2011, the State made an oral motion in limine to preclude the defense from entering evidence of mental retardation during the guilt phase of trial, and the court granted the State’s motion. The defendant subsequently filed a writ with this Court challenging that ruling. On March 22, 2011, this Court denied the writ in part and granted it in part. See, State v. Doyle , 11-K-306 (La. App. 5 Cir. 3/22/11) (unpublished writ disposition). The defendant then filed a writ with the Louisiana Supreme Court challenging this Court’s ruling. On March 23, 2011, the Louisiana Supreme Court granted the writ and found that this Court erred by requiring the trial court to give the jury a limiting instruction that it was not to consider evidence of mental retardation, defect, and/or diminished capacity as having any bearing on the defendant’s mental capacity at the time of the offense. See State v. Doyle , 11-597 (La. 3/23/11), 56 So.3d 948.
Trial commenced on March 21, 2011, and at the conclusion of trial on March 24, 2011, the defendant was found guilty as charged. The penalty phase of the trial commenced on March 25, 2011, and the jury returned a verdict of death by lethal injection. The defendant appeared for sentencing on July 25, 2011. At that time, defense counsel filed “Motion To Continue Sentencing and Omnibus Motion For New Trial, For Arrest Of Judgment, To Bar The Death Penalty And For Relief From Discrimination In Jury Selection.” The trial court denied the motion to continue sentencing and continued the remaining two motions. On July 27, 2011, the trial court denied the defendant’s motions for a new trial, arrest of judgment, and to bar the death penalty before imposing the jury’s unanimous death sentence. On August 29, 2011, the defendant filed a motion for reconsideration of sentence, which was denied by the trial court on November 2, 2011. A second motion for new trial was filed on March 28, 2012, and denied on May 1, 2013. The defendant’s motion for appeal was granted on September 22, 2014.
On November 17, 2017, the Louisiana Supreme Court issued an order that stated that it had reviewed the trial court’s determination on June 23, 2017, that the defendant was not competent to proceed on appeal. The supreme court concluded that this finding was supported by the record, and remanded the matter a second time for the trial court to determine whether the defendant was irrestorably incompetent. On March 22, 2019, in a sealed per curiam , the trial court did, in fact, determine that the defendant was irrevocably incompetent. The supreme court affirmed that finding on September 29, 2020, and remanded the case to the trial court to determine whether the defendant lacks the capacity to understand the death penalty in this case, such that he may not be executed and to determine whether resentencing was appropriate. On January 14, 2021, the district court determined that the defendant lacked the capacity to understand the death penalty such that he could not be executed and, on January 19, 2021, the defendant’s death sentence was vacated and he was resentenced to life imprisonment without the benefit of parole, probation or suspension of sentence. An order of appeal to this Court was signed by the trial court on February 1, 2021, and the instant appeal followed.
Issue
Decision
I acknowledge that facts in this case leave little doubt of Defendant’s factual guilt or culpability. However, my concern, in affirming versus vacating the jury verdict, is establishing jurisprudence that such erroneous interference with a defense’s case amounts to harmless error, when, in fact, it could be the difference in a defendant being found not guilty and not guilty because of insanity by a jury of his peers.
For the foregoing reasons, I would vacate the jury verdict on the basis that the trial court erred by prohibiting the defense from relying upon evidence of Defendant’s intellectual disability in the guilt phase of the trial and remand the matter.