State v. Hart, 80 So. 3d 25

Hart was charged by information with home invasion and found guilty by a jury.
Hart had previously been adjudicated a fourth felony offender and received a life sentence after a prior shorter term.
The record lacked the bill of information, but Hart waived formal reading and the bill was read to the jury at trial; the error was deemed harmless.
The court identified a mandatory fine under La. R.S. 14:62.8 that was not imposed and remanded to impose it.
Hart challenged the admissibility of portions of a 911 recording (confrontation issue), but the court found the error harmless given other evidence of guilt.
The court vacated the multiple offender adjudication and sentence due to identity proof deficiencies and remanded Hart for sentencing as a first offender; the State’s motion to supplement the record was denied.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Confrontation error from 911 evidence	Hart claims Crawford violation due to non-testifying witness evidence.	Hart asserts inadmissible hearsay without cross-examination.	Harmless error; evidence overall supports conviction.
Sufficiency of identity proof for 1983 armed robbery	State failed to prove Hart was the same person as the 1983 convict.	State relied on multiple bill exhibits not in record and contested fingerprint matching.	Vacate multiple offender adjudication and sentence; remand for new hearing as first offender.
Failure to impose mandatory fine under 14:62.8	Fine not imposed despite statutory requirement.	Not disputed; procedural issue.	Remand to impose the mandatory fine.
Timely informing of post-conviction rights	Court failed to inform of 930.8 rights in transcript.	Warning provided in minute entry; authority allows cure in opinion.	Advisory, not a reversible error; notes practice but not dispositive.

Crawford v. Washington, 541 U.S. 36 (U.S. 2004) (Confrontation Clause requires cross-examination for testimonial statements)
Davis v. Washington, 547 U.S. 813 (U.S. 2006) (Testimonial vs. non-testimonial 911 statements; ongoing emergency test)
Chapman v. California, 386 U.S. 18 (U.S. 1967) (Harmless-error analysis for constitutional errors)
State v. Wille, 559 So.2d 1321 (La. 1990) (Factors for harmless-error review in confrontation claims)
State v. Chaney, 423 So.2d 1092 (La. 1982) (Proof required that defendant is the same person as prior convict)
State v. Santee, 834 So.2d 533 (La. App. 4th Cir. 2002) (Missing exhibits can void multiple-offender adjudication; remand for new hearing)
State v. Williams, 859 So.2d 751 (La. App. 4th Cir. 2003) (Remand for imposition of mandatory fine when not done)
State ex rel. Glover v. State, 660 So.2d 1189 (La. 1995) (Art. 930.8 information is supplicatory; advisory relief is common)