State of Louisiana v. Timothy Gay

CourtLouisiana Court of Appeal
DecidedJune 30, 2021
Docket53,949-KA
StatusPublished

This text of State of Louisiana v. Timothy Gay (State of Louisiana v. Timothy Gay) 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. Timothy Gay, (La. Ct. App. 2021).

Opinion

Judgment rendered June 30, 2021. Application for rehearing may be filed within the delay allowed by Art. 922, La. C. Cr. P.

No. 53,949-KA

COURT OF APPEAL SECOND CIRCUIT STATE OF LOUISIANA

*****

STATE OF LOUISIANA Appellee

versus

TIMOTHY GAY Appellant

Appealed from the First Judicial District Court for the Parish of Caddo, Louisiana Trial Court No. 204,582

Honorable John Mosely, Jr., Judge

LOUISIANA APPELLATE PROJECT Counsel for Appellant By: Edward K. Bauman

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

SENAE HALL Assistant District Attorney

Before PITMAN, STONE, and BODDIE (Pro Tempore), JJ. BODDIE, J. (Pro Tempore)

In the present case, after having been convicted following a jury trial

for armed robbery of a convenience store on September 21, 1999, the

defendant, Timothy Gay, was adjudicated a third felony habitual offender.

The trial judge subsequently imposed a sentence of life imprisonment at hard

labor without the benefit of probation, parole, or suspension of sentence. On

September 17, 2020, pursuant to State ex rel. Esteen v. State, 16-0949 (La.

1/30/18), 239 So. 3d 233, Gay was resentenced under the Habitual Offender

Law to the mandatory statutory minimum of 66 years at hard labor, without

the benefit of probation, parole, or suspension of sentence. Gay filed this

appeal alleging that the sentence is constitutionally excessive. For the

following reasons, we affirm the sentence.

FACTS

On September 21, 1999, while masked and armed with a pistol, Gay

and an accomplice entered a convenience store on Line Avenue in

Shreveport, Louisiana, and stole $120 in cash and a carton of cigarettes.

Upon his arrest, Gay admitted to officers that they stole the getaway vehicle

in Waskom, Texas, and had used it for an armed robbery committed in the

Waskom area. Gay also admitted that he committed another armed robbery

of a convenience store in Shreveport.

After the jury found Gay guilty as charged, the state filed a habitual

offender bill of information based on his two 1993 convictions for felony

theft of cassette tapes and simple burglary of a truck. Gay, age 24, was

adjudicated a third-felony habitual offender under La. R.S. 15:529.1

(A)(1)(b)(ii). At that time, the habitual offender statute mandated a sentence

of life imprisonment without benefits for crimes classified under La. R.S. 14:2 as crimes of violence. “Armed Robbery” was formerly and

continues to be designated a crime of violence. La. R.S. 14:2(B)(21).

At sentencing, Gay argued that the court should impose less than the

mandatory sentence of life when his young age is taken into consideration.

In opposition, however, the prosecution noted that, in addition to Gay’s two

prior felony convictions, and the instant armed robbery conviction, he also

had multiple felony charges pending against him in other cases: burglary

(two counts), simple escape, battery of a police officer, aggravated perjury,

and another armed robbery.

In view of this criminal history, the instant conviction, and the

pending charges, the trial court found that Gay was on a crime spree, and

that a lesser sentence than the mandatory minimum of life imprisonment was

not warranted. The trial court sentenced Gay to life imprisonment without

benefits.

On appeal, Gay argued that the trial court erred by failing to impose a

sentence less than the mandatory minimum under the habitual offender

statute. State v. Gay, 34,371 (La. App. 2 Cir. 4/4/01), 784 So. 2d 714. This

court held that Gay’s sentence was not constitutionally excessive, noting that

Gay’s numerous offenses comprised “a one-man crime wave.” Id. at 716.

In view of Gay’s criminal history, including the instant armed robbery and

the other crimes to which Gay confessed, the panel concluded:

[H]e is a career criminal and a menace to society. He has no proper regard for the property or lives of others and is willing to put people in jeopardy of receiving great bodily harm or death in his pursuit of acquiring property through violent crime. ....

There is no clear and convincing demonstration that the mandated sentence is constitutionally excessive.

2 Id. at 717. Gay’s conviction and sentence were affirmed. Id.

On July 5, 2018, Gay filed a motion to correct an illegal sentence,

complaining that he was entitled to resentencing in light of Esteen, supra.

The trial court denied relief, but on supervisory review this court ruled that

the district court erred by failing to apply the 2001 ameliorative amendments

provided by La. R.S. 15:308(B) to Gay’s third-felony offender adjudication.

We reversed the ruling and remanded the matter to the district court for

application of the 2001 revisions of La. R.S. 15:529.1.

On November 4, 2019, the trial court resentenced Gay to 66 years at

hard labor without benefits, the mandatory statutory minimum under the

habitual offender statute. However, on August 14, 2020, since Gay was

resentenced without legal representation present, this court granted his writ,

vacated the sentence, and remanded the matter to the trial court to appoint

counsel for Gay before sentencing.

On September 17, 2020, Gay appeared with appointed counsel for

resentencing. Gay asked the trial court to consider granting him the benefit

of parole. The court sentenced Gay to the mandatory minimum of 66 years

at hard labor, without benefit of probation, parole, or suspension of sentence.

The sentence was imposed to run concurrently with any other sentence Gay

was serving with credit for time already served and notice of the delays to

appeal the sentence and to seek post-conviction relief.

On September 29, 2020, Gay filed a motion to reconsider sentence,

arguing that his sentence was constitutionally excessive and again asking the

trial court to grant him the benefit of parole eligibility, in light of paragraph

(G) of La. R.S. 15:529.1, which denies only the benefit of probation and

3 suspension of sentence, not parole. The court denied reconsideration, and

this appeal followed.

DISCUSSION

By his sole assignment of error, Gay alleges that the court imposed a

constitutionally excessive sentence.

Gay is currently 44 years old. He has served more than 20 years of

the original life sentence, now retroactively reduced to 66 years without

benefits. He has approximately 46 years remaining in his sentence, and he

will not be eligible for release until age 90, which, in effect, is a life

sentence.

Gay argues that the trial court “should have imposed the maximum

sentence found not to be constitutionally excessive, as opposed to the

mandatory minimum sentence.” The trial court was obligated, he maintains,

to construe the Louisiana Habitual Offender Law so as to avoid excessive

punishment, and to particularize the sentence imposed to the offender and

the offense. State v. Dorthey, 623 So. 2d 1276 (La. 1993). The 66-year

sentence for an offense committed at age 24, for $120.00 and some

cigarettes, is excessive. Gay contends that these facts show that this offense

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Related

State v. Woods
494 So. 2d 1258 (Louisiana Court of Appeal, 1986)
State v. Lewis
892 So. 2d 702 (Louisiana Court of Appeal, 2005)
State v. Dorthey
623 So. 2d 1276 (Supreme Court of Louisiana, 1993)
State v. Weaver
805 So. 2d 166 (Supreme Court of Louisiana, 2002)
State v. Owens
743 So. 2d 890 (Louisiana Court of Appeal, 1999)
State v. Johnson
709 So. 2d 672 (Supreme Court of Louisiana, 1998)
State v. Warfield
859 So. 2d 307 (Louisiana Court of Appeal, 2003)
State v. Johnson
747 So. 2d 61 (Louisiana Court of Appeal, 1999)
State v. Gay
784 So. 2d 714 (Louisiana Court of Appeal, 2001)
State v. Thurman
71 So. 3d 468 (Louisiana Court of Appeal, 2011)
State v. Dukes
57 So. 3d 489 (Louisiana Court of Appeal, 2011)
State Ex Rel. John Esteen v. State of Louisiana
239 So. 3d 233 (Supreme Court of Louisiana, 2018)
State v. Mandigo
136 So. 3d 292 (Louisiana Court of Appeal, 2014)
State v. Reese
166 So. 3d 1175 (Louisiana Court of Appeal, 2015)
Ray v. Louisiana Department of Public Safety & Corrections
192 So. 3d 760 (Supreme Court of Louisiana, 2016)
State v. Little
200 So. 3d 400 (Louisiana Court of Appeal, 2016)
State v. Sullivan
216 So. 3d 175 (Louisiana Court of Appeal, 2017)
State v. Boehm
217 So. 3d 596 (Louisiana Court of Appeal, 2017)
State v. Bailey
245 So. 3d 145 (Louisiana Court of Appeal, 2017)
State v. Turner
246 So. 3d 695 (Louisiana Court of Appeal, 2018)

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State of Louisiana v. Timothy Gay, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-louisiana-v-timothy-gay-lactapp-2021.