State v. Arceneaux, 271 So. 3d 362

Defendant convicted in 1998 of distribution of cocaine (single $20 sale); original sentence 20 years.
In 1999 he was adjudicated a third-felony offender (predicates: 1994 theft over $500; 1992 simple robbery) and resentenced to life under the then-applicable habitual-offender law; conviction affirmed on appeal.
Defendant filed a pro se motion in 2018 invoking the 2001 Act 403 ameliorative amendments and La. R.S. 15:308 (as explained in Esteen) to seek resentencing; district court granted resentencing.
At the 2018 resentencing the court imposed a 55-year enhanced sentence (near the statutory maximum under the 2001 scheme); defendant moved for reconsideration, which was denied.
On appeal defendant argued the 55-year enhanced sentence is unconstitutionally excessive; he also attempted to challenge his third-felony adjudication, but that issue was held not properly before the court.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the 55-year enhanced sentence is excessive	State: sentence within statutory range and sentencing discretion not abused	Arceneaux: 55 years is grossly disproportionate to a single $20 sale; near-maximum within 20–60 range is excessive	Court: 55-year sentence is unconstitutionally excessive and shocks the sense of justice; vacated and remanded for resentencing (suggested 30 years)
Applicable statutory sentencing scheme	State: 2001 version of La. R.S. 15:529.1 (made retroactive by La. R.S. 15:308) governs	Arceneaux: sought application of 2017 amendments (15–60 range) to reduce exposure further	Court: 2017 amendments are prospective only; 2001 version (20–60 range) applies under La. R.S. 15:308 and Esteen
Whether appellate court may revisit habitual-offender adjudication	State: habitual-offender adjudication was affirmed on prior appeal	Arceneaux: challenged adjudication again in this appeal	Court: challenge to adjudication is not properly before this second appeal; appeal limited to resentencing

State ex rel. Esteen v. State, 239 So.3d 233 (La. 2018) (explains motion to correct illegal sentence as remedy for applying Act 403 retroactively under La. R.S. 15:308)
State v. Davis, 449 So.2d 452 (La. 1984) (defines excessive punishment standard)
State v. Baxley, 656 So.2d 973 (La. 1995) (constitutional prohibition on "excessive" broadens sentencing review)
State v. Sepulvado, 367 So.2d 762 (La. 1979) (sentencing discretion must be exercised with individualization)
Solem v. Helm, 463 U.S. 277 (U.S. 1983) (sentence must relate to gravity of offense and harm to society)
State v. Clark, 391 So.2d 1174 (La. 1980) (legislative changes in penalty relevant to Eighth Amendment/excessiveness inquiry)