State of Louisiana v. Corei K. Guidry, 221 So. 3d 815

Defendant Corei K. Guidry was tried for possession with intent to distribute heroin, cocaine, and Tramadol, and conspiracy to commit simple escape; heroin charge carried 10–50 years.
Before trial the State moved in limine to prohibit informing the jury that, if convicted and later adjudicated a habitual offender, Guidry could face a life (fourth-offender) mandatory minimum; trial court denied the motion.
The State sought supervisory writs to this Court after the court of appeal declined relief; this Court granted the State’s writ and stayed trial court proceedings.
The legal question focuses on whether juries may be told of potential mandatory minimums under the Habitual Offender Law that would apply only after a post-conviction habitual-offender proceeding.
The Court concluded disclosure was improper because habitual-offender enhancement is a separate, post-conviction proceeding for the judge, too attenuated from the guilt determination to be presented to the jury.
The district court’s ruling permitting mention of the possible habitual-offender sentence was reversed and the case remanded.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Guidry)	Held
May a jury be informed, during the guilt phase, of possible mandatory minimum sentences under the Habitual Offender Law that would apply only if the State later files and prevails on a multiple bill?	Disclosure should be barred because habitual-offender enhancement is separate and speculative; trial court abused discretion by allowing mention.	Jackson and related precedent permit the court’s discretion to inform juries of penalties; allowing such disclosure prevents prosecutorial plea leverage and informs jurors of consequences.	Reversed: jury disclosure of potential habitual-offender mandatory minimums is improper — the issue is too attenuated from the guilt phase and may confuse or shift juror focus to sentencing.

State v. Jackson, 450 So.2d 621 (La. 1984) (establishes rule permitting jury notification of mandatory penalties but recognizes trial-court discretion otherwise)
State v. Harris, 247 So.2d 847 (La. 1971) (penalty is judge’s function; sentencing law generally not part of jury’s duty)
State v. Blackwell, 298 So.2d 798 (La. 1974) (discusses trial-court discretion to instruct on penalties and distinguishes capital cases)
State v. Prater, 337 So.2d 1107 (La. 1976) (plurality addressing mandatory penalties and juror notice; signaled shift from Blackwell)
State v. Milby, 345 So.2d 18 (La. 1977) (early articulation of the rule requiring notice when sentence is mandatory)
State v. Dorthey, 623 So.2d 1276 (La. 1993) (trial court retains discretion to deviate from mandatory minimums in exceptional cases)