## Facts

- James Quinn’s charred body was found in a burned building near Northwestern State College in Natchitoches; medical evidence attributed death to a gunshot wound rather than the fire.
- James Raymond (also known as James Ramos) was arrested for the homicide on November 15, 1967, and later indicted for murder.
- A jury convicted Raymond of manslaughter, and the trial court sentenced him to seven years’ imprisonment.
- Over objection, the State introduced testimony that shortly before Quinn’s death he said Raymond “wanted to have sex with him that night” and that Quinn hid to avoid being seen by Raymond.
- The trial court admitted the statement only to show Quinn’s state of mind and instructed the jury not to treat it as proof that the statement’s content was true.
- On appeal, Raymond raised multiple preserved objections, including alleged denial of a speedy trial, alleged errors in sequestration and handling of witnesses, and alleged improper admission of the victim’s statement.

## Issues

1. Whether the delay between arrest and trial violated the constitutional right to a speedy trial.
2. Whether the trial court’s management of witness sequestration constituted reversible error.
3. Whether the victim’s pre-death statement was inadmissible hearsay or unfairly prejudicial, or was admissible to show the victim’s then-existing state of mind and explain his conduct immediately before the homicide.

## Decision

- The Louisiana Supreme Court affirmed the manslaughter conviction and seven-year sentence.
- The court held the speedy-trial claim failed because the overall delay and circumstances did not establish a constitutional violation, including insufficient showing of prejudice and no record support for intentional delay to impair the defense.
- The court found no reversible error in witness sequestration rulings, emphasizing the trial judge’s broad discretion and the absence of demonstrated prejudice.
- The court upheld admission of the victim’s statement for the limited purpose of showing the victim’s state of mind and explaining conduct immediately preceding the killing, relying on the limiting instruction to prevent misuse as substantive proof.

## Legal Principles

- Speedy-trial claims require a fact-based evaluation of the length of delay, reasons for delay, the defendant’s assertion of the right, and prejudice; delay alone does not warrant dismissal without a concrete showing of harm tied to the delay.
- Witness sequestration is largely committed to the trial court’s discretion; a defendant seeking reversal must show actual prejudice from alleged sequestration irregularities.
- A victim’s out-of-court statement may be admitted to show the declarant’s then-existing state of mind and to explain subsequent conduct closely connected to the events at issue; when admitted for that limited purpose, the jury should be instructed not to treat the statement as proof of the truth of the asserted facts.

## Conclusion

The court affirmed Raymond’s manslaughter conviction, holding that the trial court neither violated the right to a speedy trial nor abused its discretion in witness sequestration, and that the victim’s pre-death statement was admissible as state-of-mind evidence with a limiting instruction to guard against hearsay use.


State v. Raymond, 245 So. 2d 335 (La. 1971)