State of Louisiana v. Courtland E. King

CourtLouisiana Court of Appeal
DecidedFebruary 19, 2025
DocketKA-0024-0367
StatusUnknown

This text of State of Louisiana v. Courtland E. King (State of Louisiana v. Courtland E. King) 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. Courtland E. King, (La. Ct. App. 2025).

Opinion

STATE OF LOUISIANA COURT OF APPEAL, THIRD CIRCUIT

24-367

STATE OF LOUISIANA

VERSUS

COURTLAND E. KING

**********

APPEAL FROM THE THIRTIETH JUDICIAL DISTRICT COURT PARISH OF VERNON, NO. 97169 HONORABLE C. ANTHONY EAVES, DISTRICT JUDGE

WILBUR L. STILES JUDGE

Court composed of Elizabeth A. Pickett, Ledricka J. Thierry, and Wilbur L. Stiles, Judges.

AFFIRMED WITH INSTRUCTIONS. Annette Fuller Roach Louisiana Appellate Project P.O. Box 6547 Lake Charles, LA 70606-6547 (337) 436-2900 COUNSEL FOR DEFENDANT/APPELLANT: Courtland E. King

Terry W. Lambright District Attorney, Thirtieth Judicial District William R. Thornton Assistant District Attorney P. O. Box 1188 Leesville, LA 71446 (337) 239-2008 COUNSEL FOR STATE/APPELLEE: State of Louisiana STILES, Judge.

On January 3, 2022, Defendant Courtland King was charged by bill of

information with one count of possession of cocaine, with an aggregate weight of

twenty-eight grams or more, and one count of possession of methamphetamine, with

an aggregate weight of twenty-eight grams or more. On September 7, 2023, a

unanimous jury found Defendant guilty of the responsive verdict of attempted

possession of cocaine, with an aggregate weight of twenty-eight grams or more, and

guilty as charged of possession of methamphetamine, with an aggregate weight of

twenty-eight grams or more. The State filed a habitual offender bill of information

on September 13, 2023, charging Defendant as a fourth or subsequent felony

offender. After a hearing held February 21, 2024, the trial court found Defendant to

be a fourth or subsequent felony offender. On March 26, 2024, the trial court

sentenced Defendant to sixty years at hard labor for attempted possession of cocaine,

with an aggregate amount of twenty-eight grams or more, and sixty years at hard

labor for possession of methamphetamine, with an aggregate weight of twenty-eight

grams or more. The sentences were ordered to run concurrently with one another,

and each is to be served without probation or suspension of sentence. Defendant now

appeals both his conviction as a habitual felony offender and his sentences.

FACTS AND PROCEDURAL HISTORY

On March 12, 2021, at approximately 2:00 a.m., Louisiana State Trooper

Isaac Davis was working patrol when he observed a vehicle cross the fog line twice.

Trooper Davis stopped the vehicle and made contact with Defendant, the driver of

the vehicle. Defendant initially gave Trooper Davis a false name and told him that

he did not have a driver’s license with him. After checking the name given to him

by Defendant and realizing that Defendant did not match the photo associated with that name, Trooper Davis asked Defendant for his real name. Defendant then gave

his correct name and birthdate. Trooper Davis learned that Defendant was driving

under a suspended license and had two active warrants against him.

Defendant gave Trooper Davis permission to search his vehicle. While

searching the front driver’s side area of the vehicle, Trooper Davis found a bag of

methamphetamine hidden under the floormat. Trooper Davis placed Defendant

under arrest and returned to continue his search of the vehicle, whereupon he

discovered a vacuum sealed brick of cocaine, a bag of loose cocaine, and another

bag of methamphetamine on the passenger side hidden under the floormat where the

center console meets the dashboard.

The State filed a Bill of Information on January 3, 2022, charging Defendant

with possession of cocaine, with an aggregate weight of twenty-eight grams or more,

in violation of La.R.S. 40:967(C), (D), and (B)(1)(b), and possession of

methamphetamine, with an aggregate weight of twenty-eight grams or more, in

violation of La.R.S. 40:967(C), (D), and (B)(1)(b). On September 7, 2023, after a

three-day jury trial, the jury found Defendant guilty of the responsive verdict of

attempted possession of cocaine, with an aggregate weight of twenty-eight grams or

more, and guilty as charged of possession of methamphetamine, with an aggregate

weight of twenty-eight grams or more.

On September 13, 2023, the State filed a Habitual Offender Bill of

Information Fourth or Subsequent Felony Offender against Defendant pursuant to

La.R.S. 15:529.1(A)(4)(a). A hearing was held on February 21, 2024, after which

the trial court found Defendant to be a fourth or subsequent felony offender for the

purposes of the habitual offender statute and scheduled a sentencing hearing for a

later date. Subsequently, on March 26, 2024, the trial court sentenced Defendant to

2 concurrent sentences of sixty years at hard labor on each count, to be served without

probation or suspension of sentence. Defendant filed a motion to reconsider sentence

which was denied by written ruling on April 17, 2024. A second motion to reconsider

sentence was filed on behalf of Defendant and was denied by written ruling on May

1, 2024.

Defendant has appealed, asserting two assignments of error:

1) The trial court erred in finding that the State had proven the predicate convictions set forth in the Habitual Offender Bill of Information as the evidence submitted as to the fifth predicate conviction established that this conviction violated the sequencing requirement of La.R.S. 15:529.1(A).

2) The sentences imposed in this case violate the Eighth Amendment of the Constitution of the United States and La. Const. Art. I, § 20, as they are nothing more than cruel and unusual punishment and, thus, excessive.

ERRORS PATENT

In accordance with La.Code Crim.P. art. 920, all appeals are reviewed for

errors patent on the face of the record. After reviewing the record, we find one error

patent and one error in the minutes of sentencing. Additionally, we note that in

assignment of error number one, Defendant alleges an error patent involving a

sequencing error in his habitual offender adjudication. We address that error patent

under our discussion of assignment of error number one.

Regarding the first error patent, we find that the trial court did not accurately

advise Defendant of the time period for filing post-conviction relief. At sentencing,

the trial court informed Defendant he had “two years from when [his] sentence

becomes final to assert any claim for post conviction relief.” (Emphasis added).

According to La.Code Crim.P. art. 930.8(A), the time period for filing post-

3 conviction relief is “two years after the judgment of conviction and sentence has

become final[.]” (Emphasis added).

A similar issue arose in State v. Folse, 23-1299, p. 11 (La.App. 1 Cir. 9/20/24),

___ So.3d ___ (2024 WL 4245979), wherein the court allowed its opinion to serve

as notice to the defendant of the correct time limitation for filing an application for

post-conviction relief, finding that the trial court’s failure to inform the defendant of

the prescriptive period for applying for post-conviction relief “is not grounds to

reverse the sentence or remand for resentencing.” Following the example set by the

court in Folse, this opinion shall serve as notice to Defendant that he has two years

from the time his judgment of conviction and sentence become final under the

provisions of La.Code Crim.P. art. 914 or 922 to file for post-conviction relief.

La.Code Crim.P. art. 930.8(A).

Next, we find that the minutes of sentencing are in need of correction.

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State of Louisiana v. Courtland E. King, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-louisiana-v-courtland-e-king-lactapp-2025.