## Facts

- On November 17, 1997, Albert “Butch” Robinson and John C. “Jack” Jackson, Jr. were each shot once inside business offices in Convent, Louisiana, during an apparent robbery attempt.
- The assailant took Robinson’s wallet and a knife, and took Jackson’s wallet and cash.
- Jackson, shot in the back, survived and called for help; Robinson was shot in the head, underwent surgery, and died the next day.
- Earlier that afternoon, Jackson interacted at the business with a well-dressed man who asked for a job application and was brought into the office to receive paperwork.
- The State’s theory was that Ronald Williams (a former employee of the business) and Glynn Juniors, Jr. planned to rob Robinson and that Juniors shot Robinson during the robbery.
- A grand jury indicted Williams and Juniors for first-degree murder; Williams pleaded guilty, received life without parole, and agreed to testify against Juniors.
- A jury convicted Juniors of first-degree murder and recommended death; the trial court imposed a death sentence.
- On direct appeal, Juniors challenged numerous rulings, including exclusion/redaction of defense-offered documents suggesting Williams as an alternative perpetrator.

## Issues

1. Whether the trial court properly redacted a hospital medical-history form to exclude the phrase stating Robinson was shot “by a disgruntled employee.”
2. Whether the trial court properly excluded an outside laboratory drug-test report from Williams’s personnel file, including an unidentified handwritten notation that Williams tested positive for marijuana.
3. Whether the conviction and death sentence were legally sustainable after review of asserted trial and penalty-phase errors.

## Decision

- The Louisiana Supreme Court affirmed Juniors’s conviction for first-degree murder and affirmed the death sentence.
- The court held the trial court acted within its discretion by redacting the “disgruntled employee” language as inadmissible hearsay within hearsay of unknown origin and reliability.
- The court held the trial court acted within its discretion by excluding the drug-test report because the proponent failed to lay a proper foundation for any business-records exception and the handwritten notation’s author was unknown.
- After reviewing the remaining assignments of error, the court found no reversible error in the guilt phase or penalty phase.

## Legal Principles

- Business and medical records may be admissible, but embedded assertions attributing fault or identifying a perpetrator must independently satisfy a hearsay exception; otherwise they may be excluded or redacted.
- Documentary evidence prepared by an outside entity generally requires a foundation from a witness with knowledge of the document’s preparation to qualify under a business-records exception.
- A document kept in a personnel file is not automatically admissible where the custodian cannot testify to the mode of preparation by the third-party preparer and where critical annotations are unattributed.
- Excluding unreliable hearsay offered by the defense does not violate the right to present a defense when ordinary evidentiary reliability requirements are applied.

## Conclusion

The court affirmed Juniors’s capital conviction and death sentence, concluding that the trial court permissibly limited defense documentary evidence as unreliable hearsay and inadequately supported business records, and that no other claimed errors warranted reversal.


State v. Juniors, 915 So. 2d 291 (La. 2005)