State v. Mosley, 54 So. 3d 692

Mosley was convicted of possession with intent to distribute marijuana and originally sentenced to 25 years at hard labor.
State filed a bill alleging Mosley was a third felony offender; the trial court found him to be a third offender and imposed life imprisonment.
In Mosley I, this Court vacated the habitual-offender finding due to lapse of the cleansing period and reinstated the original 25-year sentence.
At the second habitual-offender hearing, the court again found Mosley to be a third felony offender and imposed life in prison.
On appeal, Mosley argues the predicate pleas were improper for failing to advise him of confrontation rights; the State contends the pleas were knowingly and voluntarily made and properly documented.
The Court must determine (a) validity of the predicate pleas and Boykin-type waivers, and (b) whether the life sentence is improper given an unsettled motion to reconsider.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether predicate pleas violated confrontation rights	Mosley argues the pleas lacked Boykinized rights notice.	Mosley contends the plea forms were defective and did not inform him of confrontation rights.	No reversible error; waivers were valid and forms showed awareness of rights.
Whether the life sentence was properly imposed given procedural defects	State argues habitual status proven; sentence otherwise proper.	Mosley argues excessiveness and lack of ruling on motion to reconsider.	Habitual-offender adjudication affirmed; remanded for ruling on motion to reconsider sentence.

State v. Shelton, 621 So.2d 769 (La.1993) (burden-shifting framework for predicate pleas and Boykin waivers)
State v. Jenkins, 977 So.2d 142 (La.App. 5 Cir. 2008) (proof requirements for predicate guilty pleas and counsel representation)
State v. Otero, 31 So.3d 1125 (La.App. 5 Cir. 2010) (application of Boykin concepts to predicate pleas on appeal)
State v. Mendenhall, 944 So.2d 560 (La.2006) (confrontation-rights interpretation in plea contexts)
State v. Smallwood, 955 So.2d 1264 (La.2007) (precept on ensuring validity of pleas with respect to confrontation rights)
Bolden, 852 So.2d 1050 (La.App. 5 Cir. 2003) (remand procedure when motion to reconsider sentence is pending)
State v. Williams, 902 So.2d 485 (La.App. 4 Cir. 2005) (remand and appeal timing after ruling on motion to reconsider)
State v. Evans, 844 So.2d 111 (La.App. 5 Cir. 2003) (timing considerations on staged sentencing appeals)
State v. Brown, 750 So.2d 262 (La.App. 5 Cir. 1999) (Boykinization review and retroactivity considerations)
State ex rel. Jackson v. Henderson, 255 So.2d 89 (La.1958) (Boykin rights and trial advisement foundations)