Ensuring a Fair Hearing – Louisiana Center for Children's Rights

Ensuring a Fair Hearing

Motion for Presumption Against LWOP
Motion to Require the State to Prove Beyond a Reasonable Doubt that Defendant is Irreparably Corrupt, the “Worst Offender”, and That This is the “Worst Case”
Motion to Require the State to Prove Beyond a Reasonable Doubt that Defendant Committed the Homicide and Had the Intent to Kill
Motion Pursuant to the Sixth and Fourteenth Amendments of the U.S. Constitution to Impanel A Jury to Make the Factual Determinations Required by the Eighth Amendment and Louisiana Code of Criminal Procedure Article 878.1
Motion for Unanimous Jury Sentencing
Motion to Preclude Hearsay and Assert Rights Under the Confrontation Clause
Motion to Exclude or Limit Victim Impact Evidence
Motion to Exclude the Admissibility of Bad Acts / Aggravation (see discovery motion requesting notice)
Motion for Court to Hold that the State has Failed to Meet their Burden and Therefore the Defendant Must Receive Sentence of Life with Parole (to be filed after State has rested at Sentencing Hearing)