State v. Carter

Summary

The Louisiana Fifth Circuit Court of Appeal affirmed Steven D. Carter’s convictions and consecutive life sentences for aggravated kidnapping of a child and aggravated rape. The court held that the insanity jury instruction correctly stated Louisiana law and that admitting nude photographs of Carter was an abuse of discretion, but concluded the error was harmless in light of the overwhelming evidence of guilt. The court also advised Carter of the applicable prescriptive period for seeking post-conviction relief.

Holdings

1. The special jury instruction was a correct, pertinent statement of Louisiana law and was not erroneous, misleading, repetitive, or confusing.
2. The trial court clearly abused its discretion by admitting the nude photographs because they had no relevance or probative value to the issues at trial.
3. The erroneous admission of the nude photographs was harmless because the verdict was surely unattributable to the error.

Questions Presented

1. Whether the trial court erred by giving the State's requested special jury instruction explaining that the insanity defense requires proof of a mental disease or defect that prevented the defendant from distinguishing right from wrong, rather than mere proof of a mental disease or defect.
2. Whether the trial court erred by admitting full-frontal nude photographs of Carter taken while he was in custody.
3. If admission of the nude photographs was erroneous, whether the error was harmless.

Disposition

affirmed