State of Louisiana v. Quincy Brown

Summary

The Louisiana Supreme Court considers whether a prior juvenile delinquency adjudication obtained without a jury trial may be used to enhance an adult felony sentence under Louisiana's Habitual Offender Law. The court interprets the statute to permit such use and addresses whether the practice complies with the prior-conviction exception recognized in Apprendi v. New Jersey.

Holdings

1. Louisiana Revised Statutes § 15:529.1 was intended to treat a qualifying prior juvenile delinquency adjudication as a predicate offense for enhancement of a subsequent adult felony sentence, notwithstanding the statute's use of the phrase "second felony."
2. A juvenile adjudication obtained without a right to jury trial cannot be counted as a prior conviction or predicate offense to enhance an adult felony sentence under Louisiana's Habitual Offender Law.

Questions Presented

1. Whether Louisiana Revised Statutes § 15:529.1 permits a prior juvenile delinquency adjudication for a felony-grade offense to serve as a predicate offense for enhancement of a later adult felony sentence.
2. Whether using a juvenile adjudication obtained without a right to jury trial to increase an adult felony sentence violates the Fourteenth Amendment Due Process Clause and Apprendi v. New Jersey.

Disposition

reversed_and_remanded