STATE OF LOUISIANA VS. KENT
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The case in question concerns the defendant, Sharrieff M. Kent, who was convicted by a Plaquemines Parish jury of two counts of aggravated assault with a firearm, one count of aggravated criminal damage to property, and one count of illegal discharge of a firearm. The charges stemmed from an incident where Kent fired several shots at a pickup truck containing law enforcement officers as they were fleeing his property during an investigation. Kent claimed he was protecting his family from unknown intruders on his property.
The Court of Appeal had reversed Kent's convictions, determining that the State violated Kent's right to due process by introducing evidence of other crimes and his Fifth Amendment right to remain silent. The Court of Appeal also found that the State violated Kent’s right to remain silent by referencing his post-arrest, post-Miranda silence.
However, the Supreme Court of Louisiana disagreed with the Court of Appeal's determinations. It concluded that the references made to the officers conducting the trash pull as part of a narcotics investigation do not constitute impermissible references to other crimes or misconduct. Additionally, the Supreme Court found that the State did not violate the Fifth Amendment as the circumstances presented align more with the exceptions and non-application of Doyle than with Doyle itself.
While the Supreme Court agreed that the State introduced the facts underlying Kent's prior conviction without first satisfying necessary prerequisites to their admission, it did not believe this error warranted a reversal of Kent's conviction. Considering the overwhelming testimonial and physical evidence showing Kent fired his weapon at a fleeing vehicle in the street, the Supreme Court concluded that the verdict was surely unattributable to the error. Consequently, the Supreme Court reversed the ruling of the Court of Appeal and reinstated Kent's convictions and sentences.
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