State Of Louisiana v. Jarvis Bowie ( 2023 )

STATE OF LOUISIANA
COURT OF APPEAL, FIRST CIRCUIT
STATE OF LOUISIANA NO. 2023 KW 0605
VERSUS
JARVIS BOWIE
JTM 27, 2023
In Re: State of Louisiana, applying for
supervisory writs,
19th Judicial District Court, Parish of East Baton
Rouge, No. DC - 21- 02287.
BEFORE: LANIER, HESTER, AND MILLER, JJ.
WRIT GRANTED. The district court abused its discretion in
granting the defendant' s motion in limine to allow the defense
to cross- examine the state' s witness, Stephanie Cofield, with
regard to her unrelated criminal arrests to show bias with no
basis demonstrated beyond mere speculation.
the
A party may attack
credibility of a witness by questioning him to show bias;
however,
an arrest may not be used to impeach a witness' general
credibility. See La. Code Evid. arts. 607 and 609. 1. See also
State v. Mills, 2018- 0047 ( La. App. 1st Cir. 9/ 24/ 18), 259 So. 3d
1045, writ denied, 2018- 1686 ( La. 4/ 15/ 19), 267 So. 3d 1128.
WIL
CHH
SMN
OURT OF APPEAL, FIRST CIRCUIT
13
DEPUTY CLERK OF COURT
FOR THE COURT