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State of Louisiana v. Casey Lejeune
2024-K-0164
La. Ct. App.
May 2, 2024
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Background

  • Casey Lejeune was charged with multiple serious felonies in July 2017, including armed robbery with a firearm, possession of a firearm by a felon, and possession of methamphetamine and heroin with intent to distribute.
  • In April 2019, Lejeune pled guilty and initially received lengthy sentences but was later resentenced in September 2019 to concurrent 20-year terms after a misunderstanding about early release eligibility.
  • Lejeune filed a post-conviction application, alleging he was misled about his sentencing exposure due to misinformation from his lawyers regarding his status as a “triple lifer.”
  • Three defense attorneys testified and submitted affidavits stating they advised Lejeune he faced a mandatory life sentence, which was later discovered to be incorrect.
  • The district court granted post-conviction relief on ineffective assistance of counsel grounds, citing confusion and misinformation during the plea process.
  • The State sought review, and the appellate court was tasked with determining whether the district court erred in granting post-conviction relief and vacating Lejeune’s convictions and sentences.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Was there ineffective assistance of counsel leading to a plea? Lejeune was materially misadvised by his lawyers, affecting his decision. State claims defense counsel's advice was not below professional standards. No ineffective assistance found; attorneys negotiated a favorable plea.
Did the misinformation prejudice Lejeune’s decision to plead? Lejeune argues he would not have pled guilty but for the misadvice. State argues Lejeune cannot show he would have insisted on a trial. No prejudice proven; Lejeune failed to show he would have gone to trial otherwise.
Was granting post-conviction relief proper? Lejeune claims the plea was involuntary due to counsel's deficiency. State asserts plea was knowing and favorable given recidivist status. Relief improper; convictions and sentences reinstated.
Did counsel's misstatements about sentencing exposure matter? Misinformation led to an unfair process and an invalid plea. State argues exposure was still severe, plea was still beneficial. Court found plea agreement still favorable; misinformation did not affect the result.

Key Cases Cited

  • State v. Beatty, 391 So.2d 828 (La. 1980) (court reviews quality of counsel's representation in guilty plea challenges)
  • Strickland v. Washington, 466 U.S. 668 (1984) (sets the two-part test for ineffective assistance of counsel)
  • Hill v. Lockhart, 474 U.S. 52 (1985) (applies Strickland to guilty plea challenges based on ineffective assistance)
  • State ex rel. Jackson v. Henderson, 255 So.2d 85 (La. 1971) (required advisement of constitutional rights before accepting guilty plea)
Read the full case

Case Details

Case Name: State of Louisiana v. Casey Lejeune
Court Name: Louisiana Court of Appeal
Date Published: May 2, 2024
Citation: 2024-K-0164
Docket Number: 2024-K-0164
Court Abbreviation: La. Ct. App.