Award for Freed Prisoner Vacated by Louisiana Appellate Court
On February 20, 2008, the First Circuit Louisiana Court of Appeals vacated and remanded for further proceedings a trial court’s judgment awarding a former prisoner compensation for a wrongful conviction and imprisonment.
Calvin Williams was convicted in 1977 of first-degree murder and sentenced to life imprisonment. In 1991, Williams’ application for post-conviction relief was granted because the state failed to disclose exculpatory evidence. He was granted a new trial but the state chose not to re-try him. Williams was discharged from prison in 1992, and on August 19, 1996 the first-degree murder charge was dismissed as moot.
During a March 2007 trial on the merits of Williams’ application for compensation pursuant to Louisiana Revised Statute (La.RS) 15:572.8, the trial court prohibited the state from questioning Williams about his criminal history related to the murder charge. The state presented no witnesses and instead proffered the entire criminal record of the underlying case into evidence. The court concluded that Williams had “proven his case to the satisfaction of this court,” and awarded him $150,000 (the maximum amount allowed under La.R.S.15:572.8), along with various sums for job skills training and necessary medical and counseling services. Those payments were to be paid from the Innocence Compensation Fund.
The state appealed, asserting the trial court erred by not allowing any evidence relevant to Williams’ factual innocence. La.R.S. 15:572.8 defines “factual innocence” as “the applicant did not commit the crime for which he was convicted and incarcerated, nor did he commit any crime based on the same set of facts used in his original conviction.” The statute also contains a liberal evidentiary provision, allowing the court to “consider any relevant evidence regardless of whether it was admissible in, or excluded from, the criminal trial in which the applicant was convicted.”
Under the statute, one must not only prove the conviction was either vacated or reversed, but also that the defendant was “factually innocent” by clear and convincing evidence. The appellate court held that the trial court had erred by not allowing the state to question Williams properly. Therefore, the trial court’s judgment awarding Williams compensation was vacated and remanded for further proceedings consistent with the views expressed in the appellate court’s decision. See: In re Calvin Williams Application for Compensation Under Act # 486 of 2005, 984 So.2d 789 (La.App. 1 Cir. 2008).
Calvin Williams was convicted in 1977 of first-degree murder and sentenced to life imprisonment. In 1991, Williams’ application for post-conviction relief was granted because the state failed to disclose exculpatory evidence. He was granted a new trial but the state chose not to re-try him. Williams was discharged from prison in 1992, and on August 19, 1996 the first-degree murder charge was dismissed as moot.
During a March 2007 trial on the merits of Williams’ application for compensation pursuant to Louisiana Revised Statute (La.RS) 15:572.8, the trial court prohibited the state from questioning Williams about his criminal history related to the murder charge. The state presented no witnesses and instead proffered the entire criminal record of the underlying case into evidence. The court concluded that Williams had “proven his case to the satisfaction of this court,” and awarded him $150,000 (the maximum amount allowed under La.R.S.15:572.8), along with various sums for job skills training and necessary medical and counseling services. Those payments were to be paid from the Innocence Compensation Fund.
The state appealed, asserting the trial court erred by not allowing any evidence relevant to Williams’ factual innocence. La.R.S. 15:572.8 defines “factual innocence” as “the applicant did not commit the crime for which he was convicted and incarcerated, nor did he commit any crime based on the same set of facts used in his original conviction.” The statute also contains a liberal evidentiary provision, allowing the court to “consider any relevant evidence regardless of whether it was admissible in, or excluded from, the criminal trial in which the applicant was convicted.”
Under the statute, one must not only prove the conviction was either vacated or reversed, but also that the defendant was “factually innocent” by clear and convincing evidence. The appellate court held that the trial court had erred by not allowing the state to question Williams properly. Therefore, the trial court’s judgment awarding Williams compensation was vacated and remanded for further proceedings consistent with the views expressed in the appellate court’s decision. See: In re Calvin Williams Application for Compensation Under Act # 486 of 2005, 984 So.2d 789 (La.App. 1 Cir. 2008).
Related legal case
In re Calvin Williams Application for Compensation Under Act # 486 of 2005
| Year | 2008 |
|---|---|
| Cite | 984 So.2d 789 (La.App. 1 Cir. 2008) |
| Level | State Court of Appeals |
| Conclusion | Bench Verdict |
| Injunction Status | N/A |