Louisiana v. Mullins
Annotate this CaseThe Louisiana Supreme Court granted certiorari in this matter to determine whether the lower courts erred in allowing certain expert psychological testimony as to the victim’s intelligence quotient (IQ) and in admitting into evidence a letter written by the expert which contained hearsay evidence. Defendant Vernon Mullins was indicted for the aggravated rape of J.W. He was sentenced to life imprisonment without benefit of probation, parole, or suspension of sentence. Defendant raised issues he claimed the trial court made that warrant reversal of sentence: (1) allowing Dr. Mark Vigen, the State’s expert psychologist, to present evidence as to the results of IQ testing he did not administer or score violated the Confrontation Clause of the United States Constitution; (2) the lower courts erred in allowing hearsay testimony and the introduction into evidence of a letter Dr. Vigen prepared in advance of trial, both of which were based on information gained from persons who did not testify; (3) the lower courts erred in allowing the introduction of Dr. Vigen’s letter, where the letter contained hearsay, not subject to any exception; and (4) the court of appeal erred in failing to find that the trial court had erred in allowing expert testimony where the State failed to comply with Article 705(B) of the Code of Evidence. After review, the Supreme Court found that the letter containing the IQ test results and introduced by the State for the primary purpose of proving an essential element of the crime of aggravated rape contains testimonial statements and therefore was subject to Confrontation Clause requirements. As a result, the trial court violated defendant's Sixth Amendment rights by ruling the letter could be admitted into evidence without testimony. Furthermore, the Court found that the introduction of the letter violated the hearsay rule. Accordingly, the Court reversed the decisions below, vacated Defendant's conviction and sentence, and remanded this case to the District Court for a new trial.
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