Background
The State of Louisiana sought supervisory review of a ruling by the 19th Judicial District Court, Parish of East Baton Rouge, in a criminal matter involving August C. Payne, Jr.
The trial court had granted Payne’s motion to correct an illegal sentence. The opinion does not describe the underlying offense or the trial court’s reasoning in greater detail.
The Court’s Holding
The First Circuit granted the State’s writ application and held that, notwithstanding contrary provisions of law, the version of Louisiana’s habitual-offender statute, La. R.S. 15:529.1, that was in effect when Payne committed his instant offense governed his sentence.
Relying on La. R.S. 15:529.1(K)(1), State v. Parker, and State v. Evans, the court concluded that the trial court erred by granting Payne’s motion to correct an illegal sentence. It reversed that ruling and remanded with instructions to reinstate Payne’s life sentence in compliance with the appellate court’s ruling.
Key Takeaways
- The applicable habitual-offender statute is the version in effect when the defendant committed the instant offense.
- The trial court’s grant of Payne’s motion to correct an illegal sentence was reversed.
- On remand, the trial court must reinstate Payne’s life sentence.
Why It Matters
The decision reinforces Louisiana’s rule that sentencing under the habitual-offender statute turns on the law in force at the time of the instant offense. Courts considering post-sentencing challenges must apply that version of the statute even if later legislative changes point in a different direction.