Background of the Case
On January 30, 2022, an officer observed Clay Landis Riggs speeding on a gravel road. When the officer attempted a traffic stop, Riggs fled, leading to a 19-minute high-speed chase on rural, unpaved roads with speed limits not exceeding 30 miles per hour. The pursuit concluded when Riggs attempted to cross a narrow wooden bridge, causing his SUV to fall off and flip. Notably, Riggs had three passengers in the vehicle during this incident.
Riggs was convicted of aggravated flight from an officer and received the maximum sentence of five years at hard labor. Subsequently, he was adjudicated as a fourth felony offender, which, according to the trial court, increased his sentencing range to 20 years to life imprisonment. The court then sentenced Riggs to life imprisonment, citing his extensive criminal history, previous probation failures, apparent lack of intent to cease criminal activities, and the endangerment of his passengers during the chase.
Appeal
Riggs appealed, arguing that his life sentence was constitutionally excessive. The state countered by highlighting Riggs’s self-identification as a “sovereign citizen”—indicating his belief that laws do not apply to him—and noting his record of at least ten felony convictions.
Sentencing Ambiguity
The court identified ambiguities in Louisiana’s habitual offender statute. Due to the statutory ambiguity, the court applied the rule of lenity, which mandates resolving ambiguities in criminal statutes in favor of the defendant. Consequently, the court determined that the applicable sentencing range for Riggs was 20 years.
Judge Ellender included a dissenting opinion. He argued that the trial court correctly applied the habitual offender statute and that a life sentence was justified due to Riggs’ extensive criminal history and repeated disregard for the law. He noted that Riggs’ prior firearm convictions were later reclassified as violent crimes, which would now mandate a life sentence under current law.
The court ultimately concluded that imposing a life sentence for Riggs’s offense was grossly disproportionate, especially considering that the aggravated flight exposed him to a maximum of five years without the habitual offender enhancement. The court emphasized that while Riggs’s actions were serious, they did not warrant the maximum possible sentence.
The Court of Appeal affirmed Riggs’s conviction and his status as a fourth felony offender but vacated the life sentence. The case was remanded for resentencing in accordance with the court’s findings, setting the maximum sentence at 20 years.
The case was decided in Oct 2024 but only posted recently.
Source:
State v. Riggs, 2024 La. App. LEXIS 213 (La. Ct. App. 2024).