State v. Mead, 165 So. 3d 1044

Alvin Mead convicted in 1999 of possession of a large amount of cocaine; adjudicated a third-felony offender and sentenced to life without parole.
Mead filed a motion to vacate an illegal sentence claiming the State failed to prove the two predicate felonies were constitutionally valid (arguing his guilty pleas to the predicates were not Boykin-compliant).
The district court denied the motion; Mead sought supervisory review to challenge that denial.
The appellate court performed de novo review, considered whether the motion might be a post-conviction relief (PCR) application, and examined statutory sentencing authority as of the offense date (Oct. 5, 1997).
The court found the Habitual Offender Law and controlled-substance penalties in effect on the offense date authorized the life-without-parole sentence; it also found Mead’s Boykin-based challenge was waived for failing to raise it before sentencing and, if recharacterized as a PCR, would be time-barred and not cognizable.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Mead’s life-without-parole sentence is illegal under La. C.Cr.P. art. 882	Sentence is illegal because predicates were unconstitutionally obtained, so enhancement is invalid	Sentence is authorized by statutes in effect on offense date and contains no illegal term	Held: Sentence is legal — statutorily authorized; Article 882 relief denied
Whether using predicate convictions that lacked Boykin pleas renders the sentence void/illegal	Mead: plea colloquies for predicates were constitutionally defective, so predicates cannot be used	State: Mead failed to timely raise those challenges at habitual-offender proceedings as required by La. R.S. 15:529.1 D(1)(b); claim waived	Held: Claim waived for failing to timely object; not cognizable under Article 882
Whether the motion should be treated as a PCR application and, if so, whether it is timely	Mead seeks relief via motion; argues merits of predicate-invalidity claim	State: Motion is a disguised PCR and, if so, is untimely under La. C.Cr.P. art. 930.8	Held: Construed as PCR, application is time-barred (filed >2 years after finality)
Whether the asserted grounds (insufficient proof of Boykin waivers) are cognizable in PCR	Mead: merits-based challenge to predicate pleas	State: Claims of sentencing error at habitual-offender hearing are not reviewable in PCR; challenges must be raised on direct appeal	Held: Grounds not cognizable in PCR for habitual-offender sentencing review

Boykin v. Alabama, 395 U.S. 238 (U.S. 1969) (establishes requirement that pleas be voluntary and on the record)
State v. Campbell, 877 So.2d 112 (La. 2004) (Article 882 illegal-sentence relief may be granted at any time)
State ex rel. Smith v. Criminal Dist. Court, 646 So.2d 367 (La. 1994) (Article 882 motions not subject to the two-year PCR limitation)
State ex rel. Burger v. State, 661 So.2d 1373 (La. 1995) (motions to correct illegal sentence may be raised after conviction is final)
State v. Parker, 711 So.2d 694 (La. 1998) (habitual-offender status and sentencing limits are determined as of the date of the charged offense)
State v. Alexander, 152 So.3d 137 (La. 2014) (Article 882 relief limited to claims pointing to an illegal term; habitual-offender sentencing errors are not cognizable on PCR)
State v. Cotton, 45 So.3d 1030 (La. 2010) (habitual-offender adjudication is sentencing enhancement, not a new conviction, and is limited in PCR review)
State v. Green, 673 So.2d 262 (La. App. 4 Cir. 1996) (an illegal sentence is no sentence at all)