## Facts

- Ricko C. Ball was prosecuted under La. R.S. 14:95.1 for possessing a firearm as a person previously convicted of certain enumerated felonies.
- The predicate felony was Ball’s 1993 guilty plea to simple burglary of an inhabited dwelling, an offense listed in La. R.S. 14:95.1.
- To prove the predicate conviction and identity, the State introduced authenticated records from the prior case (bill of information, minute entry, and guilty-plea transcript) and linked Ball to the prior bill of information through fingerprint evidence.
- Before trial, Ball offered to stipulate that he had a qualifying prior felony conviction and was legally barred from possessing a firearm.
- Ball sought to prevent the jury from learning the name and nature of the prior offense; the trial court denied the motion in limine and allowed the State to present the prior-conviction records.
- The jury convicted Ball of violating La. R.S. 14:95.1.

## Issues

1. In a La. R.S. 14:95.1 prosecution, must the trial court accept a defendant’s stipulation to felon status and exclude evidence disclosing the name and nature of the predicate felony?
2. Should the reasoning of Old Chief v. United States be applied in Louisiana to require exclusion of the predicate felony’s details when the defendant offers to stipulate?

## Decision

- The Louisiana Supreme Court affirmed Ball’s conviction.
- The court declined to follow Old Chief and held it was not controlling under Louisiana evidence law.
- The trial court did not abuse its discretion by refusing the stipulation and admitting documentary proof identifying the specific predicate offense.
- The State could use properly authenticated conviction records and fingerprint evidence to prove both the enumerated predicate felony and Ball’s identity as the person convicted.

## Legal Principles

- In prosecutions under La. R.S. 14:95.1, the State must prove beyond a reasonable doubt a prior conviction for an enumerated felony and the defendant’s firearm possession within the statutory period.
- The prosecution is generally entitled to prove elements with evidence of its own choosing and is not required to accept a defendant’s stipulation in lieu of direct proof, so long as the evidence is otherwise admissible.
- Evidence identifying the specific prior felony may be materially probative where the statute applies only to enumerated offenses, making the nature of the prior conviction part of what the State must establish.
- Trial courts retain discretion under Louisiana evidentiary balancing to admit predicate-conviction records despite prejudice concerns when probative value is not substantially outweighed by unfair prejudice.
- Authenticated conviction documents, combined with reliable identification evidence such as fingerprints, are permissible to connect the defendant to the predicate conviction.

## Conclusion

The Louisiana Supreme Court held that, in a firearm-by-felon prosecution under La. R.S. 14:95.1, the State need not accept a defendant’s stipulation to felon status and may introduce documentary evidence revealing the name and nature of the predicate enumerated felony when the trial court reasonably finds the evidence admissible under Louisiana evidentiary balancing.


State v. Ball, 756 So. 2d 275 (La. 1999)