Legal Opinion · Concurrence

State of Louisiana v. Jonterry A. Bernard

Louisiana Court of Appeal

Decided September 18, 2019No. 2019-KA-0208Published

1Concurrence

STATE OF LOUISIANA * NO. 2019-KA-0208 VERSUS * COURT OF APPEAL JONTERRY A. BERNARD * FOURTH CIRCUIT * STATE OF LOUISIAN * * ******* BROWN, J., CONCURS WITH REASONS. I write separately to further address the admission of the two jail recordings after the State’s late disclosure of the recordings. In State v. Hartford, 14-0643, pp. 19-20 (La. App. 4 Cir. 3/18/15), 162 So.3d 1202, 1213, this Court explained that the harmless error analysis applies: [E]ven if the failure to provide the recorded telephone calls prior to trial was a discovery violation and the calls were erroneously admitted at…

2Cases cited5 opinions

  1. Chapman v. CaliforniaSupreme Court of the United States · 1967
  2. Sullivan v. LouisianaSupreme Court of the United States · 1993
  3. State v. HugleLouisiana Court of Appeal · 2012
  4. State v. WalkerLouisiana Court of Appeal · 2000
  5. State v. HartfordLouisiana Court of Appeal · 2015

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