State v. Arceneaux, 271 So. 3d 362

Defendant convicted (1998 jury) of distribution of cocaine for a single $20 sale; original sentence 20 years at hard labor.
In 1999 he was adjudicated a third-felony offender based on prior 1994 theft (>$500) and 1992 simple robbery; resentenced to life under the then-applicable habitual-offender statute.
In 2006 La. R.S. 15:308 made certain 2001 ameliorative amendments (Act 403) retroactive; following Esteen, defendant moved to correct an illegal sentence and was granted resentencing in 2018.
At resentencing the district court imposed a 55-year enhanced sentence (third-felony offender) without probation or suspension; defendant appealed the excessiveness of that sentence.
The appellate court reviewed proportionality considering the crime (a single small sale), the offender’s priors (one violent robbery, one theft now arguably lower-value under current law), and comparative sentences in other cases.
Court concluded the 55-year near-maximum term was grossly disproportionate and vacated the enhanced sentence, remanding for resentencing (suggesting 30 years as reasonable).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether 55-year enhanced sentence is excessive	State: sentence within statutory range for third-felony offender; discretion to impose	Arceneaux: 55 years is unconstitutionally excessive given a single $20 sale and mitigatory changes	Court: 55-year sentence is unconstitutionally excessive; vacated and remanded for resentencing (suggested 30 years)
Which version of habitual-offender statute applies	State: 2001 version (as made retroactive by La. R.S. 15:308) governs	Arceneaux: sought application of more recent 2017 amendments for lower floor	Court: 2001 version applies; 2017 amendments are prospective and inapplicable
Whether prior adjudication as third felony offender may be challenged now	State: prior adjudication already affirmed on direct appeal	Arceneaux: attempted to challenge multiple-offender adjudication again	Court: challenge is not properly before this second appeal; only resentencing review permitted
Whether legislative sentencing changes inform excessiveness review	State: sentencing discretion still broad within statutory range	Arceneaux: legislative mitigation and contemporary values support lower sentence	Court: contemporaneous legislative mitigation is relevant; used to assess proportionality and excessiveness

State v. Davis, 449 So.2d 452 (La. 1984) (defines when a sentence is excessive)
State v. Baxley, 656 So.2d 973 (La. 1995) (constitutional prohibition on excessive punishment broadens appellate sentencing review)
Solem v. Helm, 463 U.S. 277 (1983) (Eighth Amendment proportionality principle requires some relationship between crime and sentence)
State v. Sepulvado, 367 So.2d 762 (La. 1979) (limits on trial judge's discretion within statutory sentencing ranges)
State v. Clark, 391 So.2d 1174 (La. 1980) (contemporary legislative changes are relevant to Eighth Amendment proportionality analysis)
State ex rel. Esteen v. State of Louisiana, 239 So.3d 233 (La. 2018) (procedure for obtaining ameliorative Act 403 relief via motion to correct illegal sentence)
State v. Johnson, 709 So.2d 672 (La. 1998) (habitual-offender law punishes current and prior convictions)