State of Louisiana v. Christopher Raymond Diano

CourtSupreme Court of Louisiana
DecidedMarch 21, 2025
Docket2024-KK-00888
StatusPublished

This text of State of Louisiana v. Christopher Raymond Diano (State of Louisiana v. Christopher Raymond Diano) is published on Counsel Stack Legal Research, covering Supreme Court of Louisiana 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. Christopher Raymond Diano, (La. 2025).

Opinion

FOR IMMEDIATE NEWS RELEASE NEWS RELEASE #014

FROM: CLERK OF SUPREME COURT OF LOUISIANA

The Opinions handed down on the 21st day of March, 2025 are as follows:

BY Weimer, C.J.:

2024-KK-00888 STATE OF LOUISIANA VS. CHRISTOPHER RAYMOND DIANO (Parish of Terrebonne)

THE RULING OF THE DISTRICT COURT IS AFFIRMED. SEE OPINION.

Justice Jeanette Theriot Knoll, retired, heard this case as Justice Pro Tempore, sitting in the vacant seat for District 3 of the Louisiana Supreme Court. She is now appearing as Justice ad hoc for Justice Cade R. Cole.

Judge Frank H. Thaxton, III, retired, sitting ad hoc for Justice John Michael Guidry, recused.

Crain, J., dissents and assigns reasons.

McCallum, J., dissents. SUPREME COURT OF LOUISIANA

No. 2024-KK-00888

STATE OF LOUISIANA

VS.

CHRISTOPHER RAYMOND DIANO

On Supervisory Writ to the 32nd Judicial District Court, Parish of Terrebonne

WEIMER, Chief Justice1

This case addresses the proper statutory interpretation of Louisiana’s Habitual

Offender Law; specifically, calculation of the five-year cleansing period pursuant to

La. R.S. 15:529.1(C)(1). Finding the period of time defendant was incarcerated for

a misdemeanor offense is included in the calculation of the five-year cleansing

period,2 the ruling of the district court granting defendant’s motion to quash the

habitual offender bill is affirmed.

FACTS AND PROCEDURAL HISTORY

On March 3, 2023, Christopher Diano was convicted of a felony offense

(inciting a felony) committed on January 24, 2021. Following his conviction, the

State filed a bill of information seeking to adjudicate Diano as a habitual offender

1 Justice Jeanette Theriot Knoll, retired, heard this case as Justice Pro Tempore, sitting in the vacant seat for District 3 of the Louisiana Supreme Court. She is now appearing as Justice ad hoc for Justice Cade R. Cole. Judge Frank H. Thaxton, III, retired, sitting ad hoc for Justice John Michael Guidry, recused. 2 Stated another way, the days defendant spent incarcerated for a misdemeanor offense are counted, as opposed to not being counted, when evaluating whether the cleansing period of five years has elapsed. based on three predicate felony convictions dated April 7, 2009 (two counts of

possession of a controlled dangerous substance), May 6, 2010 (possession of a

controlled dangerous substance and attempted possession of a firearm by a convicted

felon), and January 7, 2013 (possession of a controlled dangerous substance). Diano

completed his parole on the three predicate offenses on December 25, 2015. Between

December 25, 2015, and January 24, 2021, when the current offense was committed,

Diano was incarcerated for approximately 180 days for a misdemeanor conviction.

Diano filed a motion to quash the habitual offender bill of information,

asserting the predicate offenses were cleansed pursuant to La. R.S. 15:529.1 because

more than five years had elapsed between his last felony conviction in 2013 and his

commission of the current felony in 2021. The State objected, arguing the five-year

cleansing period had not elapsed because the statute also provides that “any period

of ... incarceration” is not included in the computation of the five-year cleansing

period. Thus, although five years had elapsed from December 25, 2015, the date

defendant completed his parole on the three predicate offenses, and January 24, 2021,

the date of the current offense, the State took the position that the 180 days in which

Diano was incarcerated for a misdemeanor offense in 2018 and 2019 should be

excluded from calculation of the cleansing period. In response, defendant argued the

purpose of the habitual offender law is to punish multiple felonies, and time spent

incarcerated for a misdemeanor offense did not affect calculation of the five-year

cleansing period.

The district court granted Diano’s motion to quash, finding La. R.S.

15:529.1(C)(1) is properly interpreted to mean that the cleansing period is suspended

by incarceration or correctional supervision attributable only to the predicate felony

offenses listed in the habitual offender bill. The court found the State’s suggested

2 interpretation of the statutory language, i.e., incarceration for any reason suspends the

cleansing period, could lead to absurd results. The court of appeal denied the State’s

writ application. State v. Diano, 24-0206 (La. App. 1 Cir. 6/17/24) (unpublished).3

Upon the State’s application, certiorari was granted to review the correctness

of the district court’s ruling. State v. Diano, 24-00888 (La. 11/14/24), 395 So.3d

1164.

DISCUSSION

The Habitual Offender Law is set forth in La. R.S. 15:529.1. Section (A) of the

statute addresses and provides enhanced sentences for habitual offenders–i.e, persons

who commit a felony after having been previously convicted of a felony offense.

Section (C) of the statute provides for a five-year “cleansing period”4 after which the

enhancement provisions of the Habitual Offender Law cannot be used to increase the

punishment for the current offense. Relative to the dispute before the court is

Subsection (C)(1), which provides:

[T]he current offense shall not be counted as, respectively, a second, third, fourth, or higher offense if more than five years have elapsed between the date of the commission of the current offense or offenses and the expiration of the correctional supervision, or term of imprisonment if the offender is not placed on supervision following imprisonment, for the previous conviction or convictions, or between the expiration of the correctional supervision, or term of imprisonment if the offender is not placed on supervision following imprisonment, for each preceding conviction or convictions alleged in the multiple offender bill and the date of the commission of the following offense or

3 Judge Welch dissented. Based on the language of La. R.S. 15:529.1(C)(1), he found that while not a predicate offense, the defendant’s 180 days served in a penal institution in 2018 and 2019 for the misdemeanor conviction should have been excluded from the calculation of the five-year cleansing period. Judge McClendon concurred in the writ denial on this issue, and would have denied on the showing made on the State’s alternative argument (discussed infra). 4 The statute does not use the term “cleansing period.” This court previously discouraged use of that term, noting it is a misnomer and “misguided attempt to describe the intricacies of subsection (C) in a short hand manner.” State v. Everett, 00-2998, p. 7 (La. 5/14/02), 816 So.2d 1272, 1276. However, because use of the term has persisted, and its meaning in this context appears to be well understood, we will use “cleansing period” as it is employed by the parties in this case.

3 offenses. In computing the intervals of time as provided in this Paragraph, any period of parole, probation, or incarceration by a person in a penal institution, within or without the state, shall not be included in the computation of any of the five-year periods between the expiration of the correctional supervision, or term of imprisonment if the offender is not placed on supervision following imprisonment, and the next succeeding offense or offenses.

The issue this court must resolve is one of statutory interpretation, specifically

whether the statutory language–“any period ... of incarceration by a person in a penal

institution ... shall not be included in the computation” of the five-year

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