State ex rel. S.D., 149 So. 3d 917

S.D. was 16 at the January 2013 armed robbery with a dangerous weapon; he was adjudicated delinquent and placed in state custody.
On initial appeal, adjudication was affirmed but disposition was vacated; remanded to consider a new disposition.
On remand, the juvenile court again ordered secure placement with no parole, probation, suspension, or modification until age 21.
The offense involved planning, a firearm pointed at the victim’s head, and participation by another individual who struck the victim.
The court acknowledged Article 897.1(B) grants discretion on term length but subject to excessiveness review, and Article 901 guidelines do not apply to armed robbery under Article 897.1; the record supported the disposition as not excessive.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Is the disposition of secure placement until age 21 excessive?	S.D. contends the court failed to consider mitigating factors.	State argues broad discretionary authority and that record supports severity.	No manifest abuse; disposition affirmed and remanded to correct custody order.
Did the custody order properly reflect it was imposed without benefits?	S.D. asserts the order did not reflect lack of parole/probation/suspension.	State contends the transcript supports the specified conditions.	Remand for correction of the custody order to reflect lack of benefits.

State in the Interest of AM. and T.K., 739 So.2d 188 (La. 1999) (recognizes discretionary term limits for armed robbery delinquency offenses)
State v. Dorthey, 623 So.2d 1276 (La.1993) (excessiveness review governs within statutory limits)
State v. Davenport, 967 So.2d 563 (La.App. 3 Cir. 2007) (standard for reviewing abuse of sentencing discretion in juvenile cases)
State v. Cook, 674 So.2d 957 (La.1996) (abuse-of-discretion standard for sentencing within statutory limits)
State v. Pyke, 670 So.2d 713 (La.App. 3 Cir. 1996) (guides excessiveness review in juvenile dispositions)