## Facts

- Deputies responded to a reported robbery and shooting at a bank night-deposit area near Leesville, Louisiana, and found Jesse B. Pinsonneault with a gunshot wound and a spent .380 casing nearby.
- Pinsonneault, a restaurant assistant manager making a night deposit, stated a man approached from behind, shot him when he turned, took one of two deposit bags, and fled; he described the assailant as a white male in dark clothing.
- Pinsonneault was transported to hospitals and died later that morning from the gunshot wound.
- The investigation focused on Lawson Eugene Strickland and Christian Boyd, linked through Kimberly Atkins, Strickland’s girlfriend.
- Atkins testified she drove Strickland and Boyd near the bank on the night of the crime (and during a prior aborted attempt), that they exited in dark clothing with cloth tied on their heads, and that a gun was involved; she later saw them muddy, wet, and dirty.
- Atkins was arrested as an accessory after the fact and later pleaded guilty.
- While jailed, Strickland sent Atkins letters describing the crime and directing her on what to tell police; the trial court admitted the letters after redacting inflammatory material and other-crimes references.
- A jury convicted Strickland of first-degree murder, armed robbery, and conspiracy to commit armed robbery; at the penalty phase the jury unanimously recommended death based on the aggravating circumstance that the murder occurred during an armed robbery, and the trial court imposed the death sentence.

## Issues

1. Whether Louisiana law permits joinder and a single trial of a capital offense requiring a unanimous 12-person verdict with noncapital hard-labor felonies subject to a 10-of-12 concurrence rule.
2. Whether Strickland’s jail letters to Atkins were admissible after redaction, or whether their contents and other-crimes references created unfair prejudice.
3. Whether the evidence was sufficient to prove identity, specific intent, and the armed-robbery nexus supporting the first-degree murder conviction and related felonies.
4. Whether the death sentence was properly imposed under Louisiana’s capital-sentencing procedures, including review for sentencing-phase error requiring remedial proceedings.

## Decision

- The Louisiana Supreme Court affirmed Strickland’s convictions for first-degree murder, armed robbery, and conspiracy to commit armed robbery.
- The court held that joining a capital count (unanimous 12-person verdict) with noncapital hard-labor counts (10-of-12 concurrence) in a single indictment is improper under La. C.Cr.P. art. 493 and La. Const. art. I, § 17 because it creates an inconsistent mode of trial.
- Despite the joinder error identified as a matter of law, the court found no basis on this record to reverse the convictions.
- The court upheld admission of Strickland’s letters as relevant party admissions and evidence of consciousness of guilt, concluding the trial court’s redactions adequately reduced unfair prejudice.
- Applying the Jackson v. Virginia standard, the court found the evidence sufficient for a rational jury to convict beyond a reasonable doubt.
- The court conditionally affirmed the death sentence but remanded for further trial-court proceedings to develop facts and correct a specific sentencing-phase defect; the ultimate validity of the death sentence depended on the remand outcome.

## Legal Principles

- Capital and noncapital hard-labor charges with different constitutional and statutory jury-verdict requirements may not be joined in a single indictment when the joinder produces an inconsistent mode of trial under La. C.Cr.P. art. 493 and La. Const. art. I, § 17.
- A defendant’s written statements may be admitted as party-opponent admissions when relevant to guilt and efforts to influence witnesses; trial courts may redact inflammatory or other-crimes references to limit unfair prejudice.
- Evidence is constitutionally sufficient if, viewing it in the light most favorable to the prosecution, a rational trier of fact could find all essential elements beyond a reasonable doubt.
- In capital cases, the reviewing court must conduct heightened review of both conviction and sentence and may order remand to cure sentencing-phase defects while conditionally affirming the sentence.

## Conclusion

The court upheld Strickland’s convictions, ruled that capital and noncapital hard-labor counts with different jury-vote requirements are improperly joined in one indictment, affirmed the admission of redacted jail letters as probative admissions, found the evidence sufficient, and conditionally affirmed the death sentence while remanding to remedy a sentencing-phase defect.


State v. Strickland, 683 So. 2d 218 (La. 1996)