State of Louisiana v. Christopher Lee Johnson

Summary

The Louisiana Court of Appeal, First Circuit granted the State's supervisory writ application and reversed the trial court's ruling granting Christopher Lee Johnson a new trial. The court held that the video evidence was merely impeaching and that Johnson failed to show reasonable diligence in discovering it before trial, reinstating his conviction and sentence on count one and remanding for further proceedings.

Holdings

1. When considering a motion for new trial based on newly discovered evidence, the trial judge must determine the diligence shown, the truth of the matters stated, and the materiality and probability of their effect if believed true; the judge may not weigh the new evidence as though deciding the defendant's guilt or innocence as a jury.
2. Newly discovered evidence affecting only a witness's credibility and serving merely to impeach ordinarily does not support a motion for a new trial.
3. A defendant seeking a new trial based on newly discovered evidence must prove that reasonable diligence was exercised in discovering the evidence before trial.

Questions Presented

1. Whether the district court properly granted a motion for new trial under La. Code Crim. P. art. 851(B)(3) based on newly discovered video evidence.
2. Whether newly discovered evidence affecting only a witness's credibility and usable for impeachment may support a motion for a new trial.
3. Whether the defendant satisfied the reasonable-diligence requirement for newly discovered evidence.

Disposition

reversed_and_remanded