State of Louisiana v. Cedric Charles O'Neal

CourtLouisiana Court of Appeal
DecidedJune 29, 2022
Docket54,581-KA
StatusPublished

This text of State of Louisiana v. Cedric Charles O'Neal (State of Louisiana v. Cedric Charles O'Neal) is published on Counsel Stack Legal Research, covering Louisiana Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State of Louisiana v. Cedric Charles O'Neal, (La. Ct. App. 2022).

Opinion

Judgment rendered June 29, 2022. Application for rehearing may be filed within the delay allowed by Art. 922, La. C. Cr. P.

No. 54,581-KA

COURT OF APPEAL SECOND CIRCUIT STATE OF LOUISIANA

*****

STATE OF LOUISIANA Appellee

versus

CEDRIC CHARLES O’NEAL Appellant

Appealed from the First Judicial District Court for the Parish of Caddo, Louisiana Trial Court No. 198,597

Honorable Ramona L. Emanuel, Judge

LOUISANA APPELLATE PROJECT Counsel for Appellant By: Peggy J. Sullivan

CEDRIC CHARLES O’NEAL Pro Se

JAMES E. STEWART, SR. Counsel for Appellee District Attorney

LAURA O. WINGATE FULCO ALEX L. PORUBSKY NANCY F. BERGER-SCHNEIDER Assistant District Attorneys

Before PITMAN, THOMPSON, and MARCOTTE, JJ. THOMPSON, J.

Cedric Charles O’Neal was sentenced as a third felony habitual

offender to life in prison in 1999 for vehicular homicide. In 2001, the

Louisiana legislature enacted more lenient sentencing guidelines for habitual

offenders. Subsequently, pursuant to the 2006 action by the Louisiana

legislature relative to La. R.S. 15:308 and jurisprudence from the Louisiana

Supreme Court in 2018, the more lenient considerations for sentencing were

held to apply retroactively to habitual offenders sentenced prior to 2001. In

2018, O’Neal filed a motion to correct an illegal sentence, citing entitlement

to the retroactive application of the more lenient sentencing guidelines.

Finding error by the trial court in determination of O’Neal’s level of

classification as a habitual offender, as well as error as to the applicable

sentencing range for the crime of which he was convicted, we vacate his

sentence and remand to the trial court with instructions.

FACTS

On October 17, 1998, Cedric Charles O’Neal (“O’Neal”) was

tailgating outside a football game at the Fairgrounds Stadium in Shreveport,

Louisiana. He was drinking alcohol and smoking marijuana before getting

into a friend’s car to leave the tailgate to get something to eat. While he was

driving, the car in front of him stopped to let pedestrians from the game

cross Greenwood Road, and O’Neal swerved around the car at a high rate of

speed. O’Neal drove into the crowd of pedestrians and clipped Sandra

Lewis, knocking her back toward the curb. She survived. O’Neal hit Robin

Barrett (“Barrett”) with the vehicle head-on, and she was tragically killed as

a result. O’Neal was arrested and registered .112% on a Breathalyzer

administered at the time, which was above the legal limit. A later blood test revealed a blood alcohol content of .11%, and a urine test

also revealed the presence of marijuana in his body. A more detailed factual

recitation of the events that evening can be found in this court’s prior

opinion at State v. O’Neal, 34,814 (La. App. 2 Cir. 10/12/01), 795 So. 2d

1292, writ denied, 01-3207 (La. 11/1/02), 828 So. 2d 564, which also

analyzed the underlying facts of O’Neal’s conviction and resulting sentence.

PROCEDURAL HISTORY

O’Neal was charged by bill of information on December 14, 1998,

with the vehicular homicide of Robin Barrett in violation of La. R.S.

14:32.1. After a jury trial, O’Neal was found guilty and sentenced to life

imprisonment at hard labor after being adjudicated as a third felony

offender. On appeal, this court affirmed his conviction and his adjudication

as a third felony offender but vacated his sentence and remanded the matter

to the trial court for resentencing as a result of constitutional issues raised in

that appeal. O’Neal, supra. O’Neal’s convictions in his late teens of simple

burglary and possession of cocaine were the two underlying felony

convictions that elevated him to a third felony habitual offender when he

was sentenced for the vehicular homicide charge. On remand, he was again

sentenced by the trial court to life imprisonment as a third felony offender,

which O’Neal appealed. The life imprisonment sentence was later affirmed

by this court. State v. O’Neal, 36,431 (La. App. 2 Cir. 10/23/02), 830 So. 2d

408.

In 2001, the Louisiana legislature modified the severity of the

sentencing ranges for habitual offenders via Act 403 of the 2001 Regular

Session of the Legislature. In 2006, the Louisiana legislature enacted La.

R.S. 15:308, which provides for retroactive application of the more lenient 2 penalty provisions under La. R.S. 15:529.1. The Louisiana Supreme Court,

in State ex rel. Esteen v. State, 16-0949 (La. 1/30/18), 239 So. 3d 233, held

that La. R.S. 15:308 permits defendants to seek reduced sentences through a

motion to correct illegal sentence.

On May 18, 2018, O’Neal filed a motion to correct illegal sentence in

relation to his latest resentencing, citing entitlement to more lenient

sentencing considerations as directed by Esteen, supra. This court granted a

writ of mandamus on May 29, 2019, ordering the trial court to inform

O’Neal whether there was a pending filing, whether the filing had been acted

upon, and to enter a dispositive order within 30 days. O’Neal filed another

motion to correct illegal sentence on May 30, 2019. This court later granted

O’Neal’s motion to enforce the May 29, 2019 order.

In an August 22, 2019 ruling, the trial court granted O’Neal’s motion

to correct an illegal sentence, asserting that O’Neal should have been

sentenced as a second felony offender, because the cocaine possession

charge against him had been dismissed by the prosecution on February 4,

1993. The trial court stated that it attached the court minutes evidencing the

dismissal to the ruling, but the record does not include those referenced

minutes. It stated that O’Neal should have been sentenced pursuant to La.

R.S. 15:529.1(A)(1),1 and therefore, his sentencing range would be

1 A. Any person who, after having been convicted within this state of a felony, or who, after having been convicted under the laws of any other state or of the United States, or any foreign government of a crime which, if committed in this state would be a felony, thereafter commits any subsequent felony within this state, upon conviction of said felony, shall be punished as follows: (1) If the second felony is such that upon a first conviction the offender would be punishable by imprisonment for any term less than his natural life, then the sentence to imprisonment shall be for a determinate term not less than one-third the longest term and not more than twice the longest term prescribed for a first conviction.

3 imprisonment from 20 to 60 years. That assertion was inconsistent with

applicable law.

As a result of the trial court’s granting of the motion to correct illegal

sentence, a new sentencing hearing was held on January 22, 2021, and

O’Neal was resentenced by the trial court and ordered to serve 30 years’

imprisonment, with one year to be served at hard labor without the benefit of

parole, probation, or suspension of sentence. In response to his most recent

sentencing, O’Neal filed a motion to reconsider that sentence on February

10, 2021. That motion was denied by the trial court. The trial court, in its

ruling, again stated that the sentencing range for O’Neal was 20 to 60 years’

imprisonment and that O’Neal had been sentenced at the lower end of the

range.

This court granted a writ filed by O’Neal, treating his application as a

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Related

State v. Neal
830 So. 2d 408 (Louisiana Court of Appeal, 2002)
State v. O'NEAL
795 So. 2d 1292 (Louisiana Court of Appeal, 2001)
State Ex Rel. John Esteen v. State of Louisiana
239 So. 3d 233 (Supreme Court of Louisiana, 2018)

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State of Louisiana v. Cedric Charles O'Neal, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-louisiana-v-cedric-charles-oneal-lactapp-2022.