## Facts

- Deonta Gray and Jonta Gray were charged with attempted second-degree murder for shooting a taxi driver during an intended robbery.
- Before arrest, their family member arranged a motel meeting with Reverend Jeffrey Woolridge, a full-time minister and church program director, to speak with the cousins and encourage them religiously.
- In the motel room, with the family member and the other cousin present, Deonta stated they called a cab to rob the driver and shot him when the driver reached for a gun.
- Woolridge did not interrogate Deonta; he discussed the consequences of the cousins’ lifestyle and prayed with them.
- After hearing the statement, Woolridge called his superior pastor in the group’s presence; the pastor instructed Woolridge to notify authorities after leaving.
- Days later, after police contact, Woolridge voluntarily relayed Deonta’s statement to a detective.

## Issues

1. Whether Deonta’s statement to Woolridge qualified as a privileged “confidential communication” to a clergyman made for spiritual counsel, advice, or consolation under Louisiana Code of Evidence art. 511.
2. Whether the statement should be suppressed as inadmissible due to the clergy-penitent privilege.

## Decision

- The Louisiana Supreme Court reversed the court of appeal and reinstated the trial court’s denial of the motion to suppress.
- The court held the statement was not privileged under La. Code Evid. art. 511 because the circumstances did not establish a confidential spiritual consultation.
- The court concluded Deonta lacked a reasonable expectation of confidentiality given the group setting and the immediate consultation with the pastor in front of the group, including the instruction to notify law enforcement.
- The matter was remanded for further proceedings with the statement deemed admissible.

## Legal Principles

- The clergy privilege under La. Code Evid. art. 511 protects only confidential communications made to a clergyman in the clergyman’s professional character by a person seeking spiritual counsel, advice, or consolation.
- A communication is “confidential” only if made privately and not intended for further disclosure (except as needed to achieve the communication’s purpose).
- Clergy status alone does not trigger the privilege; the communicant’s purpose and the surrounding circumstances determine whether the communication is privileged.
- Communications made in a group setting, without a request for secrecy, and under circumstances signaling potential disclosure may defeat confidentiality and the privilege.
- Evidentiary privileges are construed narrowly and are not extended to cover non-confidential admissions merely because they are made in the presence of a minister.

## Conclusion

The court held that an incriminating statement made to a minister in a motel room with others present, followed by an on-the-spot call to church leadership and an instruction to notify police, was not a confidential spiritual communication protected by Louisiana’s clergyman privilege, so suppression was properly denied.


State v. Gray, 891 So. 2d 1260 (La. 2005)