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State v. Cotton

Supreme Court of Louisiana
Oct 15, 2010
45 So. 3d 1030 (La. 2010)

Summary

finding same as to ineffective assistance of counsel during multiple offender proceedings

Summary of this case from Price v. Tanner

Opinion

No. 2009-KP-2397.

October 15, 2010.

In re State of Louisiana; — Plaintiff; Applying for Supervisory and/or Remedial Writs, Parish of Jefferson, 24th Judicial District Court, Div. H., No. 04-2963; to the Court of Appeal, Fifth Circuit, No. 09-KH-766.

Prior report: La.App., 980 So.2d 34.


Writ granted. The appellate court's order granting respondent's writ and remanding the case to the district court is vacated and the district court ruling dismissing the application is reinstated. In State ex rel. Melinie v. State, 93-1380 (La.1/12/96), 665 So.2d 1172, this Court construed the provisions of La.C.Cr.P. art. 930.3 and determined that they "provide[] no basis for review of claims of excessiveness or other sentencing error post-conviction." (Emphasis added). Although respondent argues that an unreasonable delay in instituting the habitual offender proceedings provides him with a claim for post-conviction relief under La.C.Cr.P. art. 930.3(4)("The limitations on the institution of prosecution had expired."), an habitual offender adjudication does not pronounce a separate conviction or institute a separate criminal proceeding, but instead "only addresses itself to the sentencing powers of the trial judge after conviction and has no functional relationship to . . . innocence or guilt. . . ." State v. Walker, 416 So.2d 534, 536 (La. 1982); see also State v. Dorthey, 623 So.2d 1276, 1278 (La. 1993) (habitual offender bill of information "does not charge a new crime but merely advises the trial court of circumstances. . . ."). An habitual offender adjudication thus constitutes sentencing for purposes of Melinie and La.C.Cr.P. art. 930.3, which provides no vehicle for post-conviction consideration of claims arising out of habitual offender proceedings, as opposed to direct appeal of the conviction and sentence. La.C.Cr.P. art. 912(C)(1) (defendant may appeal from a judgment "which imposes sentence"). A fortiori, respondent's claim that he received ineffective assistance of counsel at his habitual offender adjudication is not cognizable on collateral review so long as the sentence imposed by the court falls within the range of the sentencing statutes. Cf. La.C.Cr.P. art. 882.

JOHNSON, J., would deny the writ.


Summaries of

State v. Cotton

Supreme Court of Louisiana
Oct 15, 2010
45 So. 3d 1030 (La. 2010)

finding same as to ineffective assistance of counsel during multiple offender proceedings

Summary of this case from Price v. Tanner

finding same as to ineffective assistance of counsel during multiple offender proceedings

Summary of this case from Williams v. Strain

In Cotton, the Louisiana Supreme Court expanded Melinie to hold that "[a]n habitual offender adjudication thus constitutes sentencing for purposes of Melinie and La.C.Cr.P. art. 930.3," and, as a result, a claim of "ineffective assistance of counsel at [an] habitual offender adjudication is not cognizable on collateral review so long as the sentence imposed by the court falls within the range of the sentencing statutes."Thomas stands for the same proposition.

Summary of this case from Gibson v. Kent

In Cotton, the Louisiana Supreme Court explained that, under Louisiana law, "an habitual offender adjudication... constitutes sentencing for purposes of Melinie and La. [Code Crim. Proc.] art. 930.3, which provides no vehicle for post-conviction consideration of claims arising out of habitual offender proceedings, as opposed to direct appeal of the conviction and sentence."

Summary of this case from Price v. Tanner

In Cotton and Thomas the Louisiana Supreme Court also applied the Article 930.3 bar to include claims of ineffective assistance of counsel during sentencing and multiple offender proceedings.

Summary of this case from Williams v. Strain

In Cotton, the Louisiana Supreme Court explained that, under Louisiana law, "an habitual offender adjudication... constitutes sentencing for purposes of Melinie and La. C. Cr. P. art. 930.3, which provides no vehicle for post-conviction consideration of claims arising out of habitual offender proceedings, as opposed to direct appeal of the conviction and sentence."

Summary of this case from Williams v. Strain

In State v. Cotton, 09-2397 (La. 10/15/10), 45 So.3d 1030, the supreme court held that ineffective assistance of counsel claims regarding sentencing are precluded from review on post-conviction.

Summary of this case from State v. Celestine

In State v. Cotton, 09–2397 (La. 10/15/10), 45 So.3d 1030, the supreme court held that ineffective assistance of counsel claims regarding sentencing are precluded from review on post-conviction.

Summary of this case from State v. Farry
Case details for

State v. Cotton

Case Details

Full title:STATE of Louisiana v. Ranji COTTON

Court:Supreme Court of Louisiana

Date published: Oct 15, 2010

Citations

45 So. 3d 1030 (La. 2010)

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Williams v. Strain

4 of 4, La. S. Ct. Writ Application, 12-KH-2038, 9/13/12 (dated 9/10/12); St. Rec. Vol. 3 of 4, La. S. Ct.…

State v. Hamlin

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