State Of Louisiana v. Jarvis Bowie

IT•

STATE OF LOUISIANA NO. 2024 KW 0740

VERSUS

JARVIS BOWIE AUGUST 19, 2024

In Re: Jarvis Bowie, applying for writs, 19th
supervisory
Judicial District Court, Parish of East Baton Rouge, No.
DC - 21- 02287.

BEFORE: WOLFE, MILLER, AND GREENE, JJ.

WRIT GRANTED IN PART AND DENIED IN PART AS MOOT. The trial
court' s ruling denying relator' s " motion to reconsider motion in
limine" with respect to Shardei Cofield is reversed. A party
attacking the credibility of a witness may examine the witness

regarding any matter having a reasonable tendency to disprove the
truthfulness or accuracy of the witness' La.
s
testimony. Code
Evid. art. 607 ( C) . To cross- examine a witness
effectively, a

defendant must be afforded the opportunity to demonstrate any bias
or self- interest attached to the witness' s testimony. See La. Code
Evid. art. 607D( 1). A witness' s hope or knowledge he will receive
leniency from the state is highly relevant to establish bias or
interest, as is the possibility the prosecution have
may some

leverage over a witness due to pending criminal charges or a plea
agreement. Thus, cross- examination regarding arrests or pending
charges may be appropriate to expose a witness' s motivation in
testifying. State v. Mills, 2018- 0047 ( La. 1st Cir. 9/ 24/ 18),
App.
259 So. 3d 1045, 1047, writ denied, 2018- 1686 ( La. 4/ 15/ 19), 267
So. 3d 1128. In the instant matter, the defense has demonstrated
that state witness, Shardei Cofield, has had pending charges in
East Baton Rouge Parish since November 16, 2018. We find that
under these circumstances, cross- examination of Shardei Cofield
regarding her pending charges may be appropriate to expose her
motivation in testifying. With respect to Stephanie Cofield, the

writ application is denied as moot in light of this court' s ruling
in State v. Bowie, 2024- 0757 ( La. 1st
App. Cir. 8/ 19/ 24)
unpublished). This matter is remanded to the trial court for
further proceedings consistent with this ruling.
EW

SMM
HG

URT OF APPEAL, FIRST CIRCUIT

UTY CLERK OF COURT
FOR THE COURT