# State v. Hatfield > Louisiana Court of Appeal · July 2, 2014 · 2013 La.App. 4 Cir. 0813 URL: https://www.frixlaw.com/law-library/cases/4816787 ## Case - **Full name:** STATE of Louisiana v. Jimmy HATFIELD - **Court:** Louisiana Court of Appeal - **Decided:** July 2, 2014 - **Citations:** 2013 La.App. 4 Cir. 0813; 155 So. 3d 572; 2014 La. App. LEXIS 1714; 2014 WL 3045096 - **Precedential status:** Published - **Opinion:** Concurrence by Bonin - **Judges:** Bonin, III, Ledet - **Cited by:** 9 later opinions in the Frix Law Library ## Citator (automated) - No negative treatment found by the automated citator. That is not the same as a confirmation that the case is good law; read the citing cases. - Full citator and citing cases: https://www.frixlaw.com/law-library/cases/4816787 ## Opinion text BONIN, J., concurs with reasons. 1,1 concur in the affirmation of Mr. Hatfield’s conviction because the prosecution has established beyond a reasonable doubt (as is its burden as the party benefitting from the errors) that the jury’s verdict is surely unattributable to the trial judge’s erroneous evidentiary rulings, and thus the errors are harmless and the trial was fair. See State v. George, 95-0110 (La.10/16/95), 661 So.2d 975, 979-80 . I am of the view, however, that the majority is too gentle in failing to state simply and directly that the trial judge’s rulings on assignments of error one and seven were erroneous. 1 It was error not to admit the medical treatise. And it was error to restrict the cross-examination of two witnesses about open warrants and pending charges. . Indeed there is no good reason to even evaluate "harmlessness” unless and until an error has been identified. See Lockhart v. Fretwell, 506 U.S. 364 , 369 n. 2, 113 S.Ct. 838 , 122 L.Ed.2d 180 (1993) ("Harmless error analysis is triggered only after the reviewing court discovers that an error has been committed.” (emphasis in original)). --- Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/4816787. Public record. Not legal advice.