Woman not allowed to change guilty plea in husband's death after split jury change
A St. Martin Parish woman who pleaded guilty to manslaughter in connection with her husband's death before the U.S. Supreme Court found split juries unconstitutional can't change her plea and opt for a trial.
The Louisiana Supreme Court said in a 5-2 ruling last week that Chrystal Clues-Alexander not knowing the U.S. Supreme Court would strike down non-unanimous juries didn't invalidate her plea.
"...Defendant correctly understood at the time she pleaded guilty that a nonunanimous jury could have convicted her if she had proceeded to trial," the court wrote in its opinion.
"Her lack of prescient knowledge that future Sixth Amendment jurisprudence would substantially alter the right to a jury trial did not make her guilty plea involuntary or unknowing or otherwise undo its binding nature."
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Clues-Alexander, a former St. Martin Parish Sheriff's deputy, was indicted on a second-degree murder charge after shooting her husband, Kendall Alexander, on Dec. 29, 2013.
Before Kendall Alexander's death in December 2013, he and Clues-Alexander had a volatile relationship with multiple reports of domestic abuse, according to court records.
Clues-Alexander pleaded guilty to a reduced charge of manslaughter in April 2018 and faces a sentence of up to 40 years.
After she pleaded guilty, the U.S. Supreme Court ruled in 2020 in Ramos v. Louisiana that juries must come to a unanimous decision to convict someone of a serious offense. Evangelisto Ramos was convicted of murder in 2016 in New Orleans by a 10-2 vote.
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Clues-Alexander filed a motion to withdraw her guilty plea. She had not yet been sentenced. She said she accepted the plea offer because the jury could have convicted her on a non-unanimous verdict.
A St. Martin Parish judge found that the Ramos ruling didn't apply and that Clues-Alexander did not reserve the right to seek an appeal of any errors.
The Third Circuit Court of Appeal disagreed with the trial court.
But the Louisiana Supreme Court said that because she was not convicted by a jury, Ramos did not apply and that the appellate court "incorrectly extended Ramos beyond its property context of convictions based on non-unanimous jury verdicts, with wide-ranging potential consequences for guilty pleas."
The Supreme Court sent Clues-Alexander's case back to St. Martin Parish for sentencing.
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Associate Justices Jefferson D. Hughes III and Piper D. Griffin were the two dissenting votes. While they agreed that Ramos does not extend to guilty pleas, they argued Clues-Alexander should have been able to withdraw her plea because it did not benefit her.
"The record is replete with numerous instances of domestic violence by Mr. Alexander against Ms. Clues, including immediately prior to the shooting," Griffin wrote in her reasoning.
"The open ended plea was of no benefit to Ms. Clues as she may still be given the maximum sentence. Further, the State concedes it would not be prejudiced by withdrawal of the guilty plea."
Contact Ashley White at adwhite@theadvertiser.com or on Twitter @AshleyyDi.
This article originally appeared on Lafayette Daily Advertiser: La. Supreme Court: Woman can't change guilty plea in husband's death
