Mark A. Williams v. State of Indiana (mem. dec.), 45A03-1702-CR-346

In November 2013 Mark A. Williams stabbed and killed Leviticus and Toshiba Dupree while stealing a shotgun; both victims died.
State charged multiple counts including two felony-murder counts (murder while perpetrating a robbery); additional counts later dismissed.
Williams pleaded guilty but mentally ill to two counts of murder while committing robbery under a plea that capped each count at the advisory term of 55 years; other charges (including habitual-offender enhancement) were dismissed.
Trial court accepted the plea, found aggravators (prior criminal history, position of trust, brutality of the crime), found no mitigators, and imposed consecutive 55-year terms (aggregate 110 years), fully executed.
Williams appealed, arguing the trial court abused sentencing discretion (improper aggravators, failure to find mitigators) and that the aggregate sentence is inappropriate under App. R. 7(B).

Issue	Plaintiff's Argument (State)	Defendant's Argument (Williams)	Held
Whether trial court abused sentencing discretion in identifying aggravating/mitigating factors	Trial court reasonably relied on valid aggravators (serious prior record, trust relationship, brutality); plea cap reflects consideration of mental illness	Court improperly repeated prior-criminal-history aggravator in different guises and failed to find mitigating factors (guilty plea, mental illness)	No abuse of discretion; prior criminal history alone is a valid aggravator, other aggravators valid, and court accounted for mental illness when accepting plea cap
Whether aggregate 110-year sentence is inappropriate under App. R. 7(B)	Sentence falls within statutory/advisory range; facts and defendant’s character justify consecutive advisory terms	Aggregate sentence excessive given defendant’s longstanding mental illness and intellectual limitations; concurrent terms would be appropriate	Sentence not inappropriate: nature of the crimes (brutal double murder of trusted family friends) and defendant’s character (violent recidivist, substance abuse, untreated mental illness) justify consecutive advisory terms

Anglemyer v. State, 868 N.E.2d 482 (Ind. 2007) (standards for appellate review of sentencing and required sentencing statement)
Cardwell v. State, 895 N.E.2d 1219 (Ind. 2008) (Appellate Rule 7(B) review focuses on culpability, severity, and aggregate sentence)
Francis v. State, 817 N.E.2d 235 (Ind. 2004) (guilty plea generally is a mitigating circumstance)
Weedman v. State, 21 N.E.3d 873 (Ind. Ct. App. 2014) (defendant must show mitigating evidence is significant and clearly supported)
Coy v. State, 999 N.E.2d 937 (Ind. Ct. App. 2013) (one valid aggravator suffices to support enhanced sentence; harmlessness of improperly applied aggravator)
Edsall v. State, 983 N.E.2d 200 (Ind. Ct. App. 2013) (prior criminal history is a valid aggravator)
Richardson v. State, 906 N.E.2d 241 (Ind. Ct. App. 2009) (advisory sentence as legislative starting point)
Corbally v. State, 5 N.E.3d 463 (Ind. Ct. App. 2014) (defendant bears burden to show sentence is inappropriate)