State of Louisiana Versus Alcus A. Smith A.K.A. "Bug" A.K.A. "Bull"

STATE OF LOUISIANA NO. 20-KA-177

VERSUS FIFTH CIRCUIT

ALCUS A. SMITH COURT OF APPEAL
A.K.A. "BUG" A.K.A. "BULL"
STATE OF LOUISIANA

ON APPEAL FROM THE TWENTY-FOURTH JUDICIAL DISTRICT COURT
PARISH OF JEFFERSON, STATE OF LOUISIANA
NO. 16-951, DIVISION "M"
HONORABLE RAYMOND C. BIGELOW, JUDGE PRO-TEMPORE

April 28, 2021

JOHN J. MOLAISON, JR.
JUDGE

Panel composed of Judges Susan M. Chehardy,
Robert A. Chaisson, and John J. Molaison, Jr.

REMANDED WITH INSTRUCTIONS
JJM
SMC
RAC

COUNSEL FOR PLAINTIFF/APPELLEE,
STATE OF LOUISIANA
Honorable Paul D. Connick, Jr.
Thomas J. Butler
Gail D. Schlosser
Douglas W. Freese
Seth W. Shute

COUNSEL FOR DEFENDANT/APPELLANT,
ALCUS A. SMITH A.K.A. "BUG" A.K.A. "BULL"
Jane L. Beebe

MOLAISON, J.

The defendant, Alcus Smith, appeals his conviction for second-degree

murder. For the following reasons, we remand the matter to the trial court with

instructions for further proceedings.

PROCEDURAL HISTORY

The defendant was indicted for the second-degree murder of Donte Hall, in

violation of La. R.S. 14:30.1, by a Jefferson Parish Grand Jury on February 25,

2016. After pleading not guilty and filing pre-trial motions,1 and following a

mistrial, the defendant ultimately proceeded to a second jury trial, during which he

was found guilty as charged on October 31, 2019. The defendant’s motion for new

trial and motion for post-verdict judgment of acquittal were both denied on

December 2, 2019, and the defendant received a life sentence to be served

concurrently with a previously imposed 60-year sentence. The instant timely

appeal follows.

FACTS

Derenne Carter testified at trial that he knew Donte Hall, the victim in this

case, and was present when Mr. Hall was killed. Mr. Carter further testified that

before Mr. Hall’s death, he participated in a drug trafficking business with the

defendant, Alcus Smith, and other individuals. He explained that before Mr. Hall’s

death, the defendant told him that he wanted to kill Mr. Hall because he believed

that Mr. Hall had set him up to be robbed during a drug deal. Mr. Carter asserted

that on the night of Mr. Hall’s shooting, the defendant picked him up in a dark-

colored vehicle and told him about the plan to kill Mr. Hall. The defendant then

drove them to Mr. Hall’s house and Mr. Hall got in the front seat. Mr. Carter

testified that Errol Brower and Richard Lee, who were friends of his, were

1
On April 2, 2019, the defendant filed a Motion to Declare Article 782(A) Unconstitutional Because It
Allows For A Non-Unanimous Verdict that was denied on April 23, 2019.
20-KA-177 1

involved in the plan to kill Mr. Hall and were following nearby in a light-colored

vehicle at that time.

Mr. Carter recalled that after the defendant picked up Mr. Hall, the light-

colored vehicle followed them and passed them “along the way.” He testified that

they eventually drove into an unfamiliar neighborhood and the defendant told Mr.

Hall they were going to pick up some guns. Mr. Carter testified that they stopped,

after which the defendant, Mr. Hall, Mr. Brower, and Mr. Lee exited their

respective vehicles. The three men then fired their guns at Mr. Hall, killing him.

Mr. Carter testified that he did not know what happened to the guns used to shoot

Mr. Hall, and he did not contact the police after the incident. Mr. Carter explained

that he and Mr. Hall were unarmed, but that defendant had a gun, which Mr. Carter

observed in the defendant’s lap when he first got into the defendant’s vehicle. He

recalled that when Mr. Hall got into the vehicle, the defendant put his gun into his

hoodie pocket.

Mr. Carter testified that he faced charges of racketeering and conspiracy to

distribute cocaine and had entered into a plea agreement that required him to

provide truthful testimony regarding anyone he was in business with, including the

defendant.

Leroy Bird testified that Mr. Hall was his “partner” and good friend and that

he knew the defendant because he had purchased drugs from him before. Mr. Bird

testified that on the day Mr. Hall was killed, but before the murder, at

approximately 6:30 or 7:00 p.m., Mr. Hall called2 and told him about a drug deal

that “went bad” the day before outside Mr. Hall’s house and that the defendant

thought Mr. Hall had something to do with it. Mr. Bird further testified that the

2
When shown phone records, which indicated that a call was made between Mr. Hall’s phone and Mr.
Bird’s phone at 6:33 p.m. for approximately two minutes, Mr. Bird testified that matched his recollection
of the phone call between him and Mr. Hall.
20-KA-177 2

defendant was going to pick Mr. Hall up and that he wanted Mr. Bird to know his

whereabouts.

Mr. Bird indicated that Mr. Hall was not behind the robbery of the

defendant. He testified that he was concerned for Mr. Hall’s safety and that he told

Mr. Hall not to go with the defendant and to wait until he got there. After the

phone call, Mr. Bird learned that Mr. Hall had been killed.

Nathan Carter testified that he engaged in narcotics trafficking with the

defendant and other individuals. Mr. Carter asserted that he became aware of Mr.

Hall’s murder after it occurred. He recalled a conversation where the defendant

told him that he had been “ripped off” in a drug deal and was angry about it. Mr.

Carter testified that the defendant told him Mr. Hall had set him up to get robbed of

some money or drugs. He also testified that the defendant told him he was going

to get Mr. Hall back. Mr. Carter explained that he told the defendant that he

should let it go because he thought it might interfere with their drug business. He

testified that the defendant called him later and told him he “took care of things”

and that it was “done.” Mr. Carter said he did not know at the time that Mr. Hall

had been killed. He asserted that he told the defendant to “lay low” but that the

defendant did not seem concerned about it because he believed nobody would

know what happened.

Marshanda Jackson testified that she knew Mr. Hall all of his life because

his great-grandmother and her grandmother were very close friends. She stated

that Mr. Hall’s grandmother lived next door to her and that Mr. Hall spent a lot of

time there. Ms. Jackson testified that she knew the defendant from coming by Mr.

Hall’s house. She recalled that the defendant came over the night before Mr. Hall

was killed and spoke to Mr. Hall. Ms. Jackson stated that she was on the porch

when the defendant drove up in a black Infiniti, which he normally drove. Ms.

20-KA-177 3

Jackson asserted that when the defendant pulled up, Mr. Hall got into the vehicle

for seven to ten minutes and then got out and left.

Ms. Jackson testified that the next day, on November 16, 2013, she and her

daughter, Mya Jackson, were at Ms. Jackson’s grandmother’s house. She recalled

that Mya and Mr. Hall were outside playing football. Ms. Jackson testified that she

saw the defendant pull up at approximately 2:00 or 3:00 p.m., after which she went

inside. Ms. Jackson asserted that Mya came inside at one point and spoke to her

about something she had seen outside. Ms. Jackson later viewed a photographic

lineup and positively identified the defendant.

Mya Jackson testified that Mr. Hall and the defendant were friends and that

she knew Mr. Hall, as they stayed next door to each other. She stated that the

defendant and Mr. Hall had been “associated” for a couple of months and that the

defendant would go to Mr. Hall’s house in his black Infiniti, which had tinted

windows and bright neon blue headlights. She found out Mr. Hall was killed on

November 16, 2013. Ms. Jackson testified that the last time she saw Mr. Hall was

that day when they were outside playing football. Ms. Jackson recalled that the

defendant arrived at the house, after which Mr. Hall went inside, retrieved his

jacket, came back outside, got into the front passenger seat of the defendant’s

vehicle, and left. She stated that when Mr. Hall got into the vehicle, she saw the

driver in the vehicle but nobody else; however, she was not looking for other

occupants in the car at that time. Ms. Jackson testified that when the defendant

pulled off, she noticed a white vehicle speed off in the same direction as the

defendant’s vehicle. She asserted that they were headed in the direction of the

Westbank Expressway toward the tunnel. Ms. Jackson stated that she went inside

and told her mother because she thought it was “kind of funny” how the white

vehicle was following the defendant’s vehicle. She testified that after she found

20-KA-177 4

out that night that Mr. Hall had been killed, she spoke to a detective. Ms. Jackson

said she was shown a photographic lineup and positively identified the defendant.

Sergeant Travis Eserman of the Jefferson Parish Sheriff’s Office (“JPSO”)

testified that he was the case officer in Mr. Hall’s murder case, and that he went to

the crime scene after a 9-1-1 call was made reporting the shooting. Sergeant

Eserman further testified that when he arrived, he observed casings on the ground

and the victim, noting that the shooting occurred on the street. He asserted that the

neighborhood where the incident happened was off of Lafitte-LaRose, on a very

isolated street.

Sergeant Eserman noted that the murder weapons and the victim’s phone

were not recovered. He stated that investigators retrieved security camera footage

from neighboring houses, parts of which were shown to the jury. Sergeant

Eserman explained that the videos showed dark and light-colored vehicles coming

into the neighborhood just before 7:00 p.m., on November 16, 2013, and then

leaving afterward. He said the video footage also showed the dark and light-

colored vehicles backing out of the location where the victim was later found in the

street.

Sergeant Eserman testified that he obtained phone records for the phones

belonging to the defendant, Mr. Hall, and Mr. Bird because he became aware of

communications between the defendant and Mr. Hall, and between Mr. Bird and

Mr. Hall. He learned that Mr. Hall called Mr. Bird approximately 27 minutes

before he was killed and that the call lasted 121 seconds. Sergeant Eserman also

learned that there were more than 50 communications between Mr. Hall and the

defendant between November 14 and 16. He stated that the last time anyone used

the phone the defendant had on November 16, 2013, was approximately 47

minutes after Mr. Hall was killed. Sergeant Eserman asserted that there was a 40-

second call at 6:26 p.m. on the night of the murder from the defendant to Mr.
20-KA-177 5

Carter, which was consistent with the information he received from Mr. Carter. He

said that he also obtained images from Facebook and Instagram that connected the

defendant to a black Infiniti-type of vehicle.

Dr. Yen Van Vo testified that she was a forensic pathologist employed by

the Jefferson Parish Coroner’s Office, and was accepted by the court as an expert

in the field of forensic pathology. Dr. Vo testified that she was qualified to review

the work of other pathologists. She further testified that she was able to formulate

her conclusions regarding the cause and manner of death in the instant case even

though she did not perform the autopsy of Mr. Hall herself. Dr. Vo asserted that

Dr. Dana Troxclair, the chief of pathology, performed Mr. Hall’s autopsy and that

she reviewed Dr. Troxclair’s autopsy report and photographs.

Dr. Vo testified that Mr. Hall’s cause of death was multiple gunshot wounds

and that the manner of death was a homicide. She explained that three wounds

would have inflicted the most severe injuries and had the greatest probability of

being fatal: 1) an entrance wound on the right side of the head with an exit wound

on the left side of the head, 2) an entrance wound on the right side of the face with

a bullet lodged in the tongue, and 3) an entrance wound on the right side of the

abdomen with a bullet lodged in the left side of the back. She stated that the range

of distance of the gunshot wounds would be a combination of distant and

indeterminate and that everything beyond 12 inches was considered distant. Dr.

Vo noted that if there were three shooters, she could not say which wounds were

caused by which shooter.

Jene Rauch testified that she worked for the JPSO crime lab as the

supervisor of the firearm and tool mark section, and as a bloodstain pattern analyst.

The State and the defense stipulated that she was an expert in the fields of firearms

examination, shooting incident reconstruction, and crime scene investigation. She

noted that the weapons used in the instant case were not recovered, which she
20-KA-177 6

explained was not uncommon. Ms. Rauch testified that she received evidence

from the autopsy. She concluded that the cartridge casings found at the scene were

fired from three separate weapons. She further concluded that one casing was fired

from a 9 mm weapon, four casings were fired from a .40 caliber weapon, and one

casing was fired from a different .40 caliber weapon. Ms. Rauch also testified that

there was evidence of at least three different guns firing projectiles at the scene.

She stated that .38 caliber class projectiles were recovered that were consistent

with a 9 mm weapon and that .40 caliber class projectiles were recovered that were

consistent with .40 caliber Smith and Wesson pistols. Ms. Rauch explained that

revolvers could have been used since they do not eject casings and that casings

could be missing because they bounced or were displaced by EMS or police.

The defense rested without calling any witnesses.

LAW AND ANALYSIS

In his first assignment of error, the defendant contends that the trial court

erred in denying his motion for post-verdict judgment of acquittal because the state

failed to prove his identity as the shooter beyond a reasonable doubt. As will be

discussed more fully below, our discovery of an error patent regarding unanimous

jury concurrence requires us to remand the matter for further proceedings.

However, we must first consider the sufficiency of the evidence, as this

determination could result in the jury’s concurrence in the verdict being

unnecessary to ascertain. State v. Raymo, 419 So.2d 858, 861 (La. 1982); State v.

Chinchilla, 20-60 (La. App. 5 Cir. 12/23/20), 307 So.3d 1189.

In reviewing the sufficiency of the evidence, an appellate court must

determine that the evidence, whether direct, circumstantial, or a mixture of both,

viewed in the light most favorable to the prosecution, was sufficient to convince a

rational trier of fact that all of the elements of the crime have been proven beyond

a reasonable doubt. Jackson v. Virginia, 443 U.S. 307, 99 S.Ct. 2781, 61 L.Ed.2d
20-KA-177 7

560 (1979); State v. Baham, 14-653 (La. App. 5 Cir. 3/11/15), 169 So.3d 558, 566,

writ denied, 15-40 (La. 3/24/16), 190 So.3d 1189. When circumstantial evidence

is used to prove the commission of the offense, La. R.S. 15:438 provides,

“assuming every fact to be proved that the evidence tends to prove, in order to

convict, it must exclude every reasonable hypothesis of innocence.” The reviewing

court is not required to determine whether another possible hypothesis of

innocence suggested by the defendant offers an exculpatory explanation of events.

Rather, the reviewing court must determine whether the possible alternative

hypothesis is sufficiently reasonable that a rational trier of fact could not have

found proof of guilt beyond a reasonable doubt. Baham, 169 So.3d at 566.

It is not the function of the appellate court to assess credibility or reweigh

the evidence. State v. Smith, 94-3116 (La. 10/16/95), 661 So.2d 442, 443. The trier

of fact shall evaluate credibility, and when faced with a conflict in testimony, is

free to accept or reject, in whole or in part, the testimony of any witness. State v.

Bradley, 03-384 (La. App. 5 Cir. 9/16/03), 858 So.2d 80, 84, writs denied, 03-2745

(La. 2/13/04), 867 So.2d 688 and 08-1951 (La. 1/30/09), 999 So.2d 750.

In the present case, the defendant was convicted of one count of second-

degree murder. In challenging the sufficiency of the evidence, the defendant does

not contest the sufficiency of the essential statutory elements; rather, he challenges

his identity as the perpetrator and asserts that the State failed to negate any

reasonable probability of misidentification.

Encompassed within proving the elements of an offense is the necessity of

proving the identity of the defendant as the perpetrator. Where the key issue is the

identification, the State is required to negate any reasonable probability of

misidentification to carry its burden of proof. State v. Ray, 12-684 (La. App. 5 Cir.

4/10/13), 115 So.3d 17, 20, writ denied, 13-1115 (La. 10/25/13), 124 So.3d 1096.

Identification by only one witness is sufficient to support a conviction. State v.
20-KA-177 8

Williams, 08-272 (La. App. 5 Cir. 12/16/08), 3 So.3d 526, 529, writ denied, 09-

0143 (La. 10/16/09), 19 So.3d 470. In the absence of internal contradiction or

irreconcilable conflict with physical evidence, one witness's testimony, if believed

by the trier of fact, is sufficient to support a requisite factual finding. State v.

Caffrey, 08-717 (La. App. 5 Cir. 5/12/09), 15 So.3d 198, 202, writ denied, 09-1305

(La. 2/5/10), 27 So.3d 297.

In State v. Cowart, 01-1178 (La. App. 5 Cir. 3/26/02), 815 So.2d 275, 284-

85, writ denied, 02-1457 (La. 5/9/03), 843 So.2d 387, there was no physical

evidence linking the defendant to the crime, and a single witness identified the

defendant as the perpetrator of a shooting. At trial, the reliability of the eyewitness

was attacked because the witness was a convicted felon, had been under

psychiatric care, had initially lied to the police, gave a description that did not

match the defendant, had perjured herself during motion hearings, and had changed

her story about the crime scene and the number of shots she heard. Despite this

long list of deficiencies, this Court held that it was within the jury's discretion to

believe the witness's testimony.

Upon review, we find that the State presented sufficient evidence to negate

any reasonable probability of misidentification of the defendant. Mr. Carter

testified that he was inside the vehicle and observed the defendant and the other

two individuals shoot and kill Mr. Hall. Ballistic evidence confirmed that three

weapons were used at the scene. Mya testified that she observed Mr. Hall get into

the vehicle with the defendant shortly before the murder. Mr. Carter testified that

the defendant wanted to retaliate against Mr. Hall. The surveillance video showed

a dark-colored vehicle and a light-colored vehicle, which matched the descriptions

of the vehicles of the defendant and the other two individuals, pull into the

neighborhood and then leave shortly after the murder. Phone records confirmed

pertinent conversations between Mr. Hall and Mr. Bird and between the defendant
20-KA-177 9

and Mr. Carter shortly before the murder. Additionally, the evidence showed that

the defendant had the specific intent to kill when he and the other individuals

pointed their guns and fired them at Mr. Hall, thereby causing Mr. Hall to sustain

nine gunshot wounds and killing him.3

In light of the foregoing, we find that a rational trier of fact could have found

that the evidence was sufficient under the Jackson standard to support the

defendant’s second-degree murder conviction. Having found that the evidence

presented was sufficient to convict the defendant of second-degree murder, we

next address an error patent on the face of the record, which requires a remand to

the trial court for further proceedings.

ERROR PATENT REVIEW

Unanimous Jury Verdict

In the instant case, the defendant was indicted for second-degree murder in

violation of La. R.S. 14:30.1, which requires that the sentence be served at hard

labor. Since the punishment for the offense is necessarily confinement at hard

labor, a jury of twelve persons was required. See La. Const. Arts I, § 17; La.

C.Cr.P. art. 782. Non-unanimous verdicts were previously allowed under these

provisions and based on the circumstances of the instant case. State v. Bertrand,

08-2215 and 08-2311 (La. 3/17/09), 6 So.3d 738, and Apodaca v. Oregon, 406

U.S. 404, 92 S.Ct. 1628, 32 L.Ed.2d 184 (1972).

However, in Ramos v. Louisiana, 590 U.S. - - , 140 S.Ct. 1390, 206 L.Ed.2d

583 (2020), the United States Supreme Court found that the Sixth Amendment

right to a jury trial—as incorporated against the states by the Fourteenth

Amendment—requires a unanimous verdict to convict a defendant of a serious

offense. For purposes of the Sixth Amendment, federal law defines serious

3
It is well established that specific intent may be inferred from the act of pointing a gun and firing at a
person. State v. Hidalgo, 95-319 (La. App. 5 Cir. 1/17/96), 668 So.2d 1188, 1197.
20-KA-177 10

offenses as offenses subject to imprisonment over six months. Accordingly,

Louisiana defendants who have been convicted of serious offenses by non-

unanimous juries and whose cases are still pending on direct review are entitled to

new trials. See, State v. Kelly, 19-425 (La. App. 5 Cir. 7/31/20), 299 So.3d 1284;

State v. Rivas, 19-378 (La. App. 5 Cir. 5/21/20), 296 So.3d 1198.

In the instant case, the concurrence of the jury verdict appears unclear based

on the record. The transcript reflects that when the jury returned to the courtroom

following deliberations, the jury foreman indicated that the defendant was found

guilty as charged. Defense counsel requested polling of the jury,4 after which a

bench conference was held. Both the transcript and the minute entry indicate that

the trial judge declared a unanimous verdict.

Our review of the polling slips indicates that while eleven (11) jurors circled

“YES” next to “Guilty as Charged,” thereby indicating their respective verdicts

were that the defendant was guilty as charged of the second-degree murder of

Donte Hall, one (1) of the jurors circled “YES” next to all three options on the

polling slip: “Guilty as Charged, Guilty of Manslaughter, and Not Guilty.” Based

on the foregoing, it is impossible to know whether the juror in question intended

her verdict to be guilty as charged, guilty of manslaughter, or not guilty and,

therefore, leaves open the question of the verdict being unanimous. Neither defense

counsel nor the State raised this issue on appeal, as the minute entry reflected a

unanimous verdict. However, Louisiana courts have repeatedly held that a jury

verdict is discoverable in the pleadings and proceedings for purposes of an error

patent review. State v. Harrell, 19-371 (La. App. 5 Cir. 7/08/20), 299 So.3d 1274,

4
The polling was done by polling slips provided to the jurors. On each slip, the following was typed:
“Is this your verdict?” “Guilty as Charged … YES or NO, Guilty of Manslaughter … YES or NO, and
Not Guilty … YES or NO”.

20-KA-177 11

1282 n. 14 (citing State v. Craddock, 307 So.2d 342 (La. 1975); State v. Sanford,

181 So.2d 50 (1965)). Furthermore, the Louisiana Supreme Court recently held

that even “if the non-unanimous jury claim was not preserved for review in the

trial court or was abandoned during any stage of the proceedings, the court of

appeal should nonetheless consider the issue as part of its error patent review.” See

State v. Gasser, 19-1220 (La. 6/3/20), 296 So.3d 1022 (per curiam); State v. Ford,

19-1221 (La. 6/3/20), 296 So.3d 1026 (per curiam); State v. Mesa, 19-1908 (La.

6/3/20), 296 So.3d 1044 (per curiam); State v. Villafranca, 19-2093 (La. 6/3/20),

296 So.3d 1057 (per curiam).

In State v. Norman, 20-0109 (La. 7/2/20), 297So.3d 738, 2020 WL 3603925

(per curiam), the Louisiana Supreme Court was faced with a similar situation in

that the polling of jurors did not make clear that the verdict was non-unanimous.

To determine whether that verdict was, in fact, unanimous, the Court remanded the

matter, ordering that the trial court “shall provide a per curiam to this Court within

ten days of ruling on the Ramos issue and stating the outcome. If the trial court

denies relief under Ramos, the defendant can appeal separately on that basis. The

remainder of the defendant's claims will be considered by this Court once the

Ramos issue is resolved.” Id.

We find Norman to be instructive in the instant case, and determine that a

remand is necessary for clarifying the record on the crucial issue of jury

concurrence. We will further pretermit the defendant’s remaining assignment of

error pending resolution of any potential Ramos issue.

DECREE

For the foregoing reasons, we remand this matter to the district court with

instructions to review the record to confirm whether the verdict was, in fact, non-

unanimous. Once confirmed, the district court shall provide this Court with a per

20-KA-177 12

curiam within 15 days of its ruling, addressing the Ramos issue and stating the

outcome of its review.

REMANDED WITH INSTRUCTIONS

20-KA-177 13

SUSAN M. CHEHARDY CURTIS B. PURSELL

CHIEF JUDGE CLERK OF COURT

NANCY F. VEGA
FREDERICKA H. WICKER
CHIEF DEPUTY CLERK
JUDE G. GRAVOIS
MARC E. JOHNSON
ROBERT A. CHAISSON SUSAN BUCHHOLZ
STEPHEN J. WINDHORST
FIRST DEPUTY CLERK
HANS J. LILJEBERG
JOHN J. MOLAISON, JR. FIFTH CIRCUIT
MELISSA C. LEDET
JUDGES 101 DERBIGNY STREET (70053)
DIRECTOR OF CENTRAL STAFF
POST OFFICE BOX 489
GRETNA, LOUISIANA 70054 (504) 376-1400

(504) 376-1498 FAX
www.fifthcircuit.org

NOTICE OF JUDGMENT AND CERTIFICATE OF DELIVERY
I CERTIFY THAT A COPY OF THE OPINION IN THE BELOW-NUMBERED MATTER HAS BEEN DELIVERED
IN ACCORDANCE WITH UNIFORM RULES - COURT OF APPEAL, RULE 2-16.4 AND 2-16.5 THIS DAY
APRIL 28, 2021 TO THE TRIAL JUDGE, CLERK OF COURT, COUNSEL OF RECORD AND ALL PARTIES NOT
REPRESENTED BY COUNSEL, AS LISTED BELOW:

20-KA-177
E-NOTIFIED
24TH JUDICIAL DISTRICT COURT (CLERK)
GAIL D. SCHLOSSER (APPELLEE) THOMAS J. BUTLER (APPELLEE) JANE L. BEEBE (APPELLANT)

MAILED
HONORABLE RAYMOND C. BIGELOW ALCUS A. SMITH #527215 (APPELLANT) HONORABLE PAUL D. CONNICK, JR.
(DISTRICT JUDGE) LOUISIANA STATE PENITENTIARY (APPELLEE)
JUDGE DIVISION "M" ANGOLA, LA 70712 DISTRICT ATTORNEY
24TH JUDICIAL DISTRICT COURT DOUGLAS W. FREESE (APPELLEE)
4TH FLOOR, SUITE 4100 SETH W. SHUTE (APPELLEE)
GRETNA, LA 70053 ASSISTANT DISTRICT ATTORNEYS
TWENTY-FOURTH JUDICIAL DISTRICT
200 DERBIGNY STREET
GRETNA, LA 70053