STATE OF LOUISIANA v. TAURUS TILLY (2026)

The defendant, Taurus B. Tilly (“Defendant”), seeks review of his convictions and sentences for manslaughter with a firearm, obstruction of justice, and unauthorized use of a motor vehicle. For the reasons that follow, we affirm Defendant's convictions and sentences.

STATEMENT OF FACTS

On March 8, 2023, Marvin Bardales Valle (“Mr. Bardales”), a Lyft driver, accepted a fare request from Defendant on the Lyft rideshare platform. Defendant was picked up on Cartier Avenue in New Orleans, Louisiana; rode as a passenger in the rear of Mr. Bardales’ vehicle; and was dropped off on Morrison Road in New Orleans, Louisiana. An altercation occurred inside the vehicle. Defendant fired a weapon, striking Mr. Bardales three times. Mr. Bardales exited the vehicle and collapsed at the nearby apartments, where he was later pronounced dead. Defendant entered the driver's seat of Mr. Bardales’ vehicle and fled the scene.

According to an affidavit for search warrant executed by Sergeant Meghan Constantine (“Sergeant Constantine”) of the New Orleans Police Department (“NOPD”), the following events transpired:

On [March 8, 2023] at approximately 2:18AM, 7th District officers responded to [Mr. Bardales] lying unresponsive in the 7000 block of Morrison in the alcove of apartment number 106A. After EMS attempted to render aid but to no avail. [Mr. Bardales] was pronounced deceased and homicide units were requested on scene.

During the course of the investigation, it was learned [Mr. Bardales] was in possession of his vehicle and two cellphones, which we[re] missing from the scene. A bulletin was sent out for the recovery of the vehicle, a white 2015 Nissan Murano LALP#103FNY.

On 3/14/2023 at approximately 12:30PM, the vehicle was located in the parking lot of the Taco Bell business located at 4603 Chef Menteur Hwy. The driver was detained and identified [as] [Defendant] (BM 12/02/2003). On his person were two cellphones: one (1) red iPhone and one (1) white iPhone. The vehicle was towed to N.O.P.D. Headquarters evidence cage for processing.

In addition to the two cellphones, NOPD officers found Mr. Bardales’ wallet in Defendant's back pocket. As part of her investigation, Sergeant Constantine obtained Lyft business records documenting that Defendant was Mr. Bardales’ last passenger on the night of the incident. After his arrest, Defendant was transported to NOPD headquarters, where he was advised of his Miranda rights using NOPD Form 153, which he acknowledged and signed. Defendant subsequently provided inculpatory statements to detectives during a custodial interrogation lasting approximately six hours. At the time of this incident and interrogation, Defendant was nineteen years old.

PROCEDURAL HISTORY

On June 8, 2023, Defendant was charged by grand jury indictment with one count of second degree murder with a firearm, a violation of La. R.S. 14:30.1; one count of obstruction of justice in a second degree murder investigation, a violation of La. R.S. 14:130.1; and one count of unauthorized use of a motor vehicle, a violation of La. R.S. 14:68.4. Defendant was arraigned and pled not guilty to all charges.

On October 2, 2023, Defendant filed several pretrial motions, including a motion to suppress statements he provided to law enforcement during his custodial interrogation. Two days later, the trial court conducted a hearing on Defendant's motion to suppress statements. At the hearing, Sergeant Constantine testified regarding the circumstances of Defendant's arrest, Miranda advisement, and subsequent interrogation. After taking the matter under advisement, the trial court denied the motion to suppress on November 30, 2023. In its written ruling, the trial court specifically noted:

Here, although the interrogation of Mr. Tilly was not without defects, this court finds that Mr. Tilly's statements were not improperly induced. Detective Meghan Constantine testified that she read Mr. Tilly his Miranda rights, which Mr. Tilly acknowledged. Although Mr. Tilly was detained for over six hours and did resort to urinating in a trashcan after asking for assistance to go to the bathroom, he was given water and food when he requested it. When Mr. Tilly informed a detective that his handcuff was hurting him, an officer loosened the cuff. Mr. Tilly can be heard talking to himself throughout the periods in which he is alone in the interrogation room. Later, Mr. Tilly informed detectives that he experiences mental health disorders. However, those mental health disorders do not necessitate that Mr. Tilly could not properly waive his Miranda rights.[] Not unlike the interrogators in Blank[1], detectives did urge Mr. Tilly to make a statement and tell the truth. Further, detectives induced Mr. Tilly to provide them with cell phone passcodes by suggesting he would be incarcerated longer if he did not give them the codes. However, this inducement is not improper because, like the interrogators in Blank, detectives never promised Mr. Tilly anything in exchange for the codes.[] Therefore, under the totality of the circumstances, Mr. Tilly's statements were freely and voluntarily given. Thus, his statements must not be suppressed.

On June 27, 2024, Defendant filed a motion seeking special jury instructions regarding the mandatory sentence for second degree murder, self-defense, the burden of proof in connection with self-defense, and human trafficking. Thereafter, on July 26, 2024, the trial court denied Defendant's motion to the extent he sought a jury instruction on the human trafficking. Defendant sought supervisory writs in connection with those rulings; the writ applications were denied by both this Court and the Louisiana Supreme Court.

A four-day jury trial commenced with jury selection on February 3, 2025, and concluded on February 6, 2025, with the jury finding Defendant guilty of the responsive verdict of manslaughter with a firearm, obstruction of justice, and unauthorized use of a motor vehicle. On April 7, 2025, Defendant filed a motion for new trial and a motion for appeal. Ten days later, the trial court denied Defendant's motion for new trial and granted his motion for appeal. On the same day, after defense counsel waived sentencing delays, the trial court sentenced Defendant to twenty years without the benefit of probation, parole, or suspension of sentence as provided by the firearm sentencing enhancement pursuant to La. C.Cr.P. art. 893.3(E) on the manslaughter conviction; twenty years on the obstruction of justice conviction; and two years on the unauthorized use of a motor vehicle conviction, with the sentences to run concurrently and credit for time served. This appeal followed.

ERRORS PATENT

In accordance with La. C.Cr.P. art. 920(2), all appeals are reviewed for errors patent on the face of the record. A review of the record reveals no errors patent.

DISCUSSION

On appeal, Defendant assigns two errors for this Court's review: (1) the trial court erred in denying the defense motion to suppress Defendant's custodial statement, which was obtained in violation of his Fifth and Sixth Amendment rights; and (2) the trial court erred in denying the defense-requested jury instruction on second-degree kidnapping, which was necessary for a fair adjudication of the justification defense.

Assignment of Error Number 1: Motion to Suppress Custodial Statement

As his first assignment of error, Defendant contends the trial court erred in denying his motion to suppress his custodial statement. “The district courts are afforded great discretion when ruling on motions to suppress, such that an appellate court will not disturb a district court's ruling on a motion to suppress absent an abuse of that discretion.” State v. Hill, 2025-0316, p. 10 (La. App. 4 Cir. 8/19/25), 418 So.3d 1119, 1127 (citation omitted). Considering that a motion to suppress presents a mixed question of law and fact, appellate courts review the underlying facts for an abuse of discretion and the conclusions drawn from those facts de novo. Id. at p. 11, 418 So.3d at 1127. However, when the facts are uncontroverted, “the appellate court need only ‘consider whether the trial court came to the proper legal determination under the undisputed facts.’ ” Id. (quotation omitted).

The Fifth Amendment to the United States Constitution protects persons from compelled self-incrimination. Before conducting a custodial interrogation, law enforcement must advise a suspect of his right to remain silent, his right to the presence of an attorney, and that any statement he makes may be used against him. Miranda v. Arizona, 384 U.S. 436, 444-45, 86 S.Ct. 1602, 1612, 16 L.Ed.2d 694 (1966). A defendant may waive these rights, but the waiver must be made “voluntarily, knowingly, and intelligently.” Id., 384 U.S. at 444, 86 S.Ct. at 1612.

On a motion to suppress a confession or statement, the burden rests with the State to prove admissibility. La. C.Cr.P. art. 703(D). A confession or statement is inadmissible unless it was made freely and voluntarily, without the “influence of fear, duress, intimidation, menaces, threats, inducements, or promises.” La. R.S. 15:451. The ultimate inquiry is whether, under the totality of the circumstances, the defendant's will was overborne. Schneckloth v. Bustamonte, 412 U.S. 218, 226, 93 S.Ct. 2041, 2047, 36 L.Ed.2d 854 (1973). In assessing voluntariness, courts consider the youth of the accused, his level of education or intelligence, whether he was advised of his constitutional rights, the length of detention, whether the interrogation was repeated or prolonged, whether physical punishment was employed, and the individual characteristics of the accused. Id. No single factor is dispositive; the inquiry requires a holistic assessment of the circumstances. Id.

At the suppression hearing conducted on October 4, 2023, Sergeant Constantine testified regarding the circumstances of Defendant's arrest and subsequent interrogation. Sergeant Constantine testified that following Defendant's arrest, he was transported to NOPD headquarters and placed in an interview room. After completing standard administrative paperwork, detectives advised Defendant of his Miranda rights using NOPD Form 153. Defendant acknowledged those rights and signed the form. The interrogation then proceeded.

On appeal, Defendant's sole challenge is to the voluntariness of his post-advisement waiver, not to the advisement itself. This concession is of considerable significance and materially affects the issues presented for review. The execution of NOPD Form 153 satisfies the State's initial burden under La. C.Cr.P. art. 703(D) and establishes a strong presumption of validity that Defendant must overcome. He has not done so.

Defendant's principal argument is that the six-hour duration of the interrogation was inherently coercive. We disagree. “[N]othing suggests that the duration of the interrogation, without more, render[s] it involuntary.” State v. Blank, 2004-0204, p. 13 (La. 4/11/07), 955 So.2d 90, 105. The relevant inquiry is whether the extended interrogation, combined with other circumstances, stripped Defendant of his free will. In this matter, the record reflects no such combination. Defendant was provided food upon request. When Defendant complained that a handcuff was causing physical discomfort, an officer promptly loosened it. During periods when Defendant was alone in the interview room, he could be heard speaking to himself in a composed manner. The record contains no evidence of sleep deprivation, threats, promises of leniency, physical punishment, or any conduct by law enforcement designed to psychologically overwhelm Defendant.

Defendant also contends that his disclosure, during the interrogation, that he experiences mental health disorders renders his waiver involuntary. This argument is without merit. The existence of a mental health condition does not invariably establish that a defendant lacked the capacity to make a knowing and voluntary waiver of Miranda rights. State v. Brooks, 1992-3331, p. 12 (La. 1/17/95), 648 So.2d 366, 373. The controlling inquiry is whether the mental condition, as it actually existed at the time of the waiver, rendered Defendant incapable of understanding and exercising his rights. The record before us contains no expert testimony, psychiatric evaluation, or other competent proof establishing that Defendant's mental health condition was of such a character or severity as to preclude a knowing and voluntary waiver at the time of the interrogation. Critically, detectives did not exploit the disclosure. Defendant's conduct throughout the interrogation – including his coherent, narrative account of the events of the night and his composed demeanor during breaks – demonstrates intact comprehension.

Finally, Defendant's age – nineteen years old at the time of the interrogation – is a recognized Schneckloth factor, but youth alone does not by itself invalidate a Miranda waiver. Defendant was a legal adult. The record contains no evidence that his age, considered together with any of the other circumstances, rendered him unable to exercise his free will.

Assessing the totality of the circumstances, the trial court's determination that Defendant's statements were freely and voluntarily given is supported by competent evidence in the record. The trial court – having observed the surveillance video of the interrogation, heard the testimony of Sergeant Constantine, and assessed her credibility firsthand – did not abuse its discretion in denying the motion to suppress. Consequently, this assignment of error is without merit.

Assignment of Error Number 2: Special Jury Instructions

As his second assignment of error, Defendant asserts that the trial court erred in denying the defense-requested jury instruction on second degree kidnapping, which was necessary for a fair adjudication of the justification defense. Regarding jury instructions, a trial court must charge the jury “[a]s to the law applicable to the case.” La. C.Cr.P. art. 802. Louisiana Code of Criminal Procedure Article 807 provides:

A requested special charge shall be given by the court if it does not require qualification, limitation, or explanation, and if it is wholly correct and pertinent. It need not be given if it is included in the general charge or in another special charge to be given.

Moreover, a special jury charge must be supported by the evidence. State v. Craig, 1995-2499, p. 7 (La. 5/20/97), 699 So.2d 865, 869 (citation omitted). “[F]ailure to give a requested jury instruction constitutes reversible error only when there is a miscarriage of justice, prejudice to substantial rights of the accused, or a substantial violation of a constitutional or statutory right.” State v. Perkins, 2013-1917, p. 2 (La. 9/3/14), 149 So.3d 206, 208.

At the conclusion of testimony, defense counsel requested that the jury be charged with respect to second degree kidnapping. The trial court denied Defendant's request. Pertinent to this matter, second degree kidnapping is defined as imprisoning or forcibly secreting any person wherein he or she is physically or sexually abused. La. R.S. 14:44.1A(3). Under this statute, “sexually abused” is defined as the victim being “subjected to any sex offense as defined in R.S. 15:541.”

Defendant maintains the crux of his defense was that Mr. Bardales prevented him from exiting the vehicle with the intent of sexually assaulting him; therefore, he was justified in killing Mr. Bardelas in order to protect himself. However, the trial court previously granted Defendant's motion seeking a special jury instruction regarding self-defense. The trial court ruled it would provide the jury with the “treatise version” of instructions in connection with self-defense and the burden of proof in connection with self-defense. The special jury instruction on self-defense essentially covered the same ground as an instruction regarding second degree kidnapping would have covered as applied to this case. Therefore, under La. C.Cr.P. art. 807, the trial court did not err in its refusal to include a special jury instruction on second degree kidnapping. Accordingly, this assignment of error also lacks merit.

CONCLUSION

For the foregoing reasons, we affirm the Defendant's convictions and sentences for manslaughter with a firearm, obstruction of justice, and unauthorized use of a motor vehicle.

AFFIRMED

FOOTNOTES

1.   The trial court is referring to the Louisiana Supreme Court case, State v. Blank, 2004-0204 (La. 4/11/07), 955 So.2d 90.

Judge Nakisha Ervin-Knott