State of Louisiana v. Desmond C. Parker

Summary

The court held that the State failed to prove that defendant's prior out-of-state guilty plea included an express waiver of each of the three constitutional rights implicated by a guilty plea. Because the State's documentary evidence showed only a waiver of the right to a jury trial and the State offered no additional proof, the prior plea could not support fourth-felony-offender adjudication. The court affirmed defendant's adjudication as a third-felony offender.