State v. Randall, 51 So. 3d 799

Randall was adjudicated a third-offender and sentenced to five years without probation, parole, or suspension after a March 2009 multiple-offender hearing.
The State previously sought to convict him as a fourth offender but later amended to a third offender; original sentence was vacated and increased.
Exhibits S-1 through S-5 were introduced at the hearing; several could not be located for inclusion in the appellate record.
Defense counsel raised limited objections; the record shows objection to the admission of exhibits but not to discharge-date proof.
The court corrected the sentence to ensure it was served without probation/parole; transcript controlled over minute entries.
Appellate proceedings included issues about the sufficiency of proof of predicate convictions and ineffective assistance, culminating in affirmance of the adjudication and an amended sentence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the sentence must be corrected for parole prohibition	Randall contends the sentence may be improper due to parole prohibition.	Equal concern that proper service terms be followed; error patent exists.	Yes; parole prohibition must be deleted from the sentence.
Whether discharge dates of predicate convictions were properly proven	State bears duty to prove valid predicate convictions and discharge dates.	Defense objected or preserved on related issues; lack of discharge-date objection may foreclose review.	Lack of objection on discharge dates precludes review; evidence showed cleansing period did not expire.
Whether counsel was ineffective for not objecting to discharge-date proof	Ineffective assistance if failure to object prejudiced Randall.	No prejudice shown; incarceration shortened cleansing period, so objection would have failed.	No prejudice; ineffective-assistance claim rejected.
Whether exhibits S-2 through S-5 should have been part of the appellate record/affect review	Exhibits were essential to review of the multiple-bill hearing.	Exhibits unavailable; supplements moot once copies surfaced in related case.	Issue moot; exhibits ultimately not required for review.

State v. Rideau, 947 So.2d 127 (La. 4th Cir. 2006) (transcript controls over conflicting minute entry in sentencing)
State v. Kirkling, 904 So.2d 786 (La. 4th Cir. 2005) (statutory sentencing considerations for multiple offenders)
State v. Cossee, 678 So.2d 72 (La. App. 4th Cir. 1996) (burden on defendant to challenge predicate convictions; outlines 15:529.1 procedures)
State v. Juengain, 41 So.3d 499 (La. App. 4th Cir. 2010) (lack of discharge-date objection precludes review)
State v. Anderson, 728 So.2d 14 (La. App. 4th Cir. 1998) (oral objections may preserve identity/validity challenges)