Date: 10-24-2024

Case Style:

State of Louisiana v. Charles L. Williams

Case Number: 549-728

Judge: Kimya M. Holmes

Court: Criminal District Court, Orleans Parish, Louisiana

Plaintiff's Attorney: New Orleans Louisiana District Attorney's Office

Defendant's Attorney:

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Description:

New Orleans, Louisiana criminal defense lawyer represented the Defendant charged with felony carnal knowledge of a juvenile - a violation of La. R.S. 14:80.

On September 1,2020, Charles Williams ("Defendant") was charged with one count of felony carnal knowledge of a juvenile - a violation of La. R.S. 14:80 - as it relates to G.B. for the time period between August 13, 2012 and August 13, 2015.[1],[2] Additionally, Defendant was charged with one count of enticing G.B., who was under eighteen years old, into prostitution by placing, persuading, encouraging or causing the entrance of G.B. into prostitution, either by force, threats, promises, or by any other device - a violation of La. R.S. 14:86 - for the time period between August 13, 2015 and September 21, 2019.

Several pre-trial motions and notices were filed in this case. However, pertinent to this writ application, the State filed State's First Notice of Intent to Offer Evidence of Similar Crimes, Wrongs, and Acts by the Defendant at the Time of Trial Under La. Code of Evidence Article 404(B) ("Notice") on July 24, 2024, which Defendant opposed. Through its Notice, the State attempted to introduce evidence pertaining to allegations made by G.B.'s sister on October 8, 2018, regarding a sexual encounter she had with Defendant on that same date.

According to G.B.'s sister, on October 8, 2018, Defendant picked her up from her house and brought her to his residence so that she could do work for his small business and earn extra money for her school dance expenses. As she sat on the sofa at Defendant's house, Defendant began rubbing on her back and kissing her. From there, Defendant performed oral sex on her and eventually proceeded to vaginally penetrate her. G.B.'s sister started crying, and Defendant ceased his sexual actions. Defendant drove her home and gave her money. During the drive home, G.B.'s sister texted her friend about what occurred, and the friend reported the encounter to G.B.'s sister's family. Once at home, her family confronted her about the information her friend disclosed to them, and one of the family members called 911. At the time of this incident, G.B.'s sister was seventeen years old.

After learning of Defendant's sexual encounter with G.B.'s sister on October 8, 2018, G.B. reported Defendant's abuse to law enforcement on October 15, 2018. According to G.B., Defendant began sexually abusing her when she was fourteen years old, and their sexual activity continued until the age of twenty. As an adult, G.B. would receive money from Defendant after sex, and she continued having sex with Defendant to prevent him from sexually assaulting her younger sisters.

As part of the investigation into G.B.'s sister and G.B.'s allegations, Defendant was interviewed by the investigating detective. Regarding the encounter with G.B.'s sister, he admitted to touching, kissing, performing oral sex, and vaginally penetrating her. However, he stopped when she started crying and stated she did not give him the impression "that [was] something she didn't want to do." Shifting to G.B.'s allegations, Defendant admitted to having a sexual relationship with G.B., but stated she was seventeen when they started having sex. Defendant also admitted to having a close relationship with G.B. and that he sometimes gave her money. Defendant claimed G.B.'s allegations are revenge for his sexual encounter with her sister.

In connection with the Notice, the State was seeking to introduce evidence related to Defendant's sexual encounter with G.B.'s sister, which included affidavits for arrest warrants - along with the actual arrest warrants - connected with Defendant's arrest for crimes against G.B. (first-degree rape and enticing prostitution) and G.B.'s sister (third-degree rape)[3], and Defendant's video-recorded statement to the investigating detective.

The trial court conducted a hearing on August 5, 2024 regarding the State's Notice and took the matter under advisement. Eleven days later, the trial court ruled to exclude the evidence that was the subject of the State's Notice. Defendant now seeks supervisory review of the trial court's ruling excluding the La. C.E. art. 404(B) evidence.

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State v. Williams, 2024-K-0591 (La. App. Oct 24, 2024)

Outcome: Judgement reversed.

Plaintiff's Experts:

Defendant's Experts:

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