State of Louisiana v. Kenneth Wilson

Summary

The Louisiana Supreme Court held that the defendant was entitled to resentencing after his first-degree robbery conviction was reduced to simple robbery. The court vacated the mandatory life sentence and remanded for the district court to determine whether the sentence was constitutional and appropriate in light of the reduced conviction, the nonviolent prior offenses, and applicable habitual-offender law principles. Two justices dissented, and one assigned separate dissenting reasons.

Holdings

1. When an appellate court reduces a defendant's conviction, the case must be remanded to the district court for imposition of a new sentence so that the trial judge can sentence the defendant with full knowledge of the offense of conviction.
2. On remand, Wilson was entitled to present evidence and argument that the mandatory life sentence was unconstitutionally excessive in light of the reduced conviction, the nonviolent nature of his prior offenses, and other circumstances of the case; the district court had the duty to make that determination under the governing excessive-sentence principles.

Questions Presented

1. Whether the court of appeal erred by affirming the mandatory life sentence without remanding for the district court to resentence Wilson after reducing his conviction from first degree robbery to simple robbery.
2. Whether Wilson was entitled to present to the district court arguments and evidence that the mandatory life sentence was unconstitutionally excessive as applied to him.

Disposition

vacated