State v. Buckley, 88 So. 3d 482

Buckley was convicted of aggravated battery and later subjected to a habitual offender, i.e., multiple bill, proceeding.
A prior single aggravated battery conviction (Nov. 13, 2007) led to a five-year sentence on Mar. 19, 2008.
The State filed a second and then a second multiple-bill (August 27, 2010) alleging Buckley as a fourth felony offender.
The multiple bill hearing was repeatedly continued due to court/jury schedules, transportation issues, competency evaluations, and other administrative delays.
Fingerprint testing linked Buckley to prior offenses; ultimately, on Oct. 7, 2010, the court adjudicated him a fourth-felony offender and imposed a twenty-year sentence (mandatory minimum).
Buckley appeals, challenging (1) the delay in the multiple-bill hearing, (2) the adjudication as a fourth offender, and (3) the adequacy and propriety of the resulting sentence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was the delay in the multiple-bill hearing unconstitutional?	Buckley argues the delay violated due process.	State contends delay was within discretionary bounds given continuances and hearings.	No reversible error; delay did not violate due process.
Was Buckley properly adjudicated a fourth-felony offender?	Buckley contends insufficiency of proof and possible waiver of rights.	State proved prior qualifying felonies and identity; no waiver defect.	Buckley properly adjudicated a fourth-felony offender.
Is the twenty-year mandatory minimum sentence constitutionally excessive or improperly justified?	Buckley contends sentence excessive and not adequately explained; argues constitutional issues with mandatory minimum.	Court need not detail every 894.1 factor when sentence is mandatory; standard review supports validity.	Sentence within statutory limits and constitutionally permissible; no abuse of discretion.

Barker v. Wingo, 407 U.S. 514 (U.S. 1972) (speedy trial four-factor framework)
State v. Muhammad, 875 So.2d 45 (La. 2004) (timeliness of filing and hearing in habitual offender proceedings)
State v. Rainey, 43 So.3d 1090 (La.App. 4 Cir. 2010) (speedy-trial considerations in habitual offender context)
State v. Jefferson, 922 So.2d 577 (La.App. 4 Cir. 2005) (courts need not enumerate every 894.1 factor when sentence is mandatory)
State v. Johnson, 709 So.2d 672 (La. 1998) (presumption of constitutionality of mandatory minimums; exceptional departure required)
State v. Douglas, 952 So.2d 793 (La.App. 4 Cir. 2007) (guidelines 894.1 factors need not be enumerated; focus on factual basis for sentence)
State v. Lindsey, 770 So.2d 339 (La. 2000) (precedent on habitual offender sentencing)
State v. Love, 847 So.2d 1198 (La. 2003) (standard for appellate review of sentencing)
State v. Grimes, 786 So.2d 876 (La. App. 4 Cir. 2001) (abuse of discretion standard in appeals)