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