Louisiana v. JacksonAnnotate this Case
Defendant Leroy Jackson was found guilty of armed robbery and two counts of attempted armed robbery based solely on his identification by the two victims, Adrian Maldonado and Wilson Vargas, and an eyewitness to the crimes, Anibal Maldonado. The offenses were committed in 2009, by three armed men. Two of the men wore masks. Defendant was identified as the unmasked man after the witnesses collaborated with an officer to make a computerized composite of him. A detective proposed placing defendant in a photographic lineup based on the composite. The three witnesses then each identified defendant from a photographic lineup. The two victims expressed uncertainty, however, in their identifications to a defense investigator. After defendant was found guilty by the jury, the district court sentenced him to 50 years imprisonment at hard labor as a second-felony offender for armed robbery, and two terms of 24 years imprisonment at hard labor for attempted armed robbery, with the sentences to run concurrently and without benefit of parole, probation, or suspension of sentence. After conducting an evidentiary hearing, however, the district court granted defendant a new trial. In ruling, the district court emphasized the problematic nature of cross-racial identifications, and the strong indications here that the identifications were unreliable. The court of appeal reversed. Defendant appealed, arguing he received ineffective assistance of trial counsel because counsel was provided with information that undermined the witness identifications, in a case that rested entirely on the witness identifications, but did not use it. The Louisiana Supreme Court reversed the court of appeal and reinstated the district court’s ruling that granted defendant a new trial.