STATE OF LOUISIANA v. CHRISTOPHER ALEXANDER (2026)

Relator, Christopher M. Alexander, seeks supervisory review of the district court's ruling denying his application for post-conviction relief. As we find Relator has not demonstrated his claim for ineffective assistance of counsel, we grant Relator's writ, but deny relief.

On May 10, 2018, Relator was indicted in Criminal District Court for the Parish of Orleans, of one count of second degree murder and one count of obstruction of justice. On March 24 2022, a jury convicted Relator of second degree murder and obstruction of justice. The district court sentenced him to concurrent terms of life imprisonment at hard labor “without benefit of probation, parole, or suspension of sentence,” and twenty-five years imprisonment at hard labor. This Court affirmed the convictions and sentences, and our Supreme Court denied writs. State v. Alexander, 2023-0540 (La.App. 4 Cir. 4/23/24), 401 So.3d 105; State v. Alexander, 2024-00665 (La. 12/11/24) 396 So.3d 968.¹ On March 13, 2026, Relator filed an application for post-conviction relief in the district court. The application was denied. Relator now seeks review in this Court.

Relator claims that the district court erred when it denied his claim that his trial counsel failed to file a motion to quash after the Louisiana Supreme Court reversed the district court's ruling denying his motion to suppress. See State v. Alexander, 2018-1772 (La. 12/3/18), 257 So.3d 672. After the trial, Relator appealed his convictions and sentences to this Court. This Court held that there was sufficient evidence to support the defendant's conviction of second degree murder and obstruction of justice, affirming the jury's verdict.

On post-conviction review, Relator maintains that under the “fruits of the poisonous tree” doctrine, his counsel should have moved to quash the affidavit for his arrest and the bill of indictment, since both were produced from his statements that were deemed “involuntary” by the Louisiana Supreme Court. He further asserts that his counsel's failure to challenge the validity of the affidavit and bill of indictment was a violation of his constitutional rights.

To prevail on a claim of ineffective assistance of counsel,

[f]irst, the defendant must show that counsel's performance was deficient. This requires showing that counsel made errors so serious that counsel was not functioning as the “counsel” guaranteed the defendant by the Sixth Amendment [to the U.S. Constitution]. Second, the defendant must show that the deficient performance prejudiced the defense. This requires showing that counsel's errors were so serious as to deprive the defendant of a fair trial, a trial whose result is reliable.

Strickland v. Washington, 466 U.S. 668, 687, 104 S.Ct. 2052, 2065, 80 L.Ed.2d 674 (1984). In the event the defendant fails to make an adequate showing on one of the components, it is unnecessary to address the others. State ex rel. Byrd v. State, 2016-0574, p. 3 (La. 8/4/17), 223 So.3d 1150, 1151. To carry his burden of proof that counsel's errors deprived the defendant of a fair trial, the defendant must show that a reasonable probability exists that the result would have been different but for counsel's deficient performance. State v. Reichard, 2005-1262, p. 5 (La. App. 4 Cir. 6/21/06), 935 So.2d 727, 730-31. “[A] reasonable probability is a probability sufficient to undermine confidence in the outcome.” Id., 2005-1262, p. 5, 935 So.2d at 731 (quoting Strickland, 466 U.S. at 693, 104 S.Ct. at 2068).

The crux of Relator's argument on post-conviction review is that his counsel failed to file a motion to quash the charges on remand from the Louisiana Supreme Court. When reviewing the case on direct appeal, this Court thoroughly analyzed the State's evidence and found the evidence sufficient to establish Relator's guilt. Specifically, we explained:

The circumstantial evidence discussed above proved collateral facts and circumstances from which the existence of the primary fact, that defendant was the shooter, could be inferred according to reason and common expertise. The state showed that defendant was jealous that Ms. Mims was in a relationship with the victim. Further, defendant was in the area, an area he was very familiar with, where the murder took place. His account that he was there to meet a stripper was far-fetched and clearly not supported by competent evidence. Viewing the circumstantial evidence in a light most favorable to the prosecution, a rational trier of fact could have found that the state proved defendant's identity as the killer. Defendant's claim that the state presented insufficient evidence to support his second degree murder conviction is without merit.

Alexander, 2023-0540, p. 14-15, 401 So.3d at 114.

The facts do not suggest that the State's admissible evidence was derived from prosecutorial misconduct. Failure to file a motion to quash does not amount to ineffective assistance of counsel. Relator fails to show that his counsel acted improperly by failing to challenge the validity of the warrant for arrest and bill of indictment. As set forth above, the State's evidence was sufficient to prove Relator's guilt beyond a reasonable doubt and any challenge to the sufficiency of the charging document or arrest warrant would almost certainly have been meritless and, in any event, did not render his ensuing trial unfair or the jury's verdict suspect. Accordingly, Relator's writ application is granted, but relief denied.

WRIT GRANTED; RELIEF DENIED

FOOTNOTES

1.   The United States Supreme Court denied certiorari. Alexander v. Louisiana. ___ U.S. ___, 145 S.Ct. 2780 (2025), 222 L.Ed.2d 1077.

Judge Tiffany Gautier Chase

BELSOME, C. J., CONCURS IN THE RESULT