We investigate the influence of laser phase noise heating on resolved sideband cooling in the context of cooling the center-of-mass motion of a levitated nanoparticle in a high-finesse cavity. Although phase noise heating is not a fundamental physical constraint, the regime where it becomes the main limitation in Levitodynamics has so far been unexplored and hence embodies from this point forward the main obstacle in reaching the motional ground state of levitated mesoscopic objects with resolved sideband cooling. We reach minimal center-of-mass temperatures comparable to T_{min}=10 mK at a pressure of p=3×10^{-7} mbar, solely limited by phase noise. Finally we present possible strategies towards motional ground state cooling in the presence of phase noise.