State of Louisiana v. Daron Dejuan Adams, 293 So.3d 1187

On April 20, 2018, Daron Dejuan Adams shot Sharman Shehee in the head with a handgun; the victim sustained significant medical injuries and requested a maximum sentence.
Adams was originally charged with attempted second-degree murder but pled guilty to the reduced offense of aggravated second-degree battery (La. R.S. 14:34.7) on April 8, 2019; there was no sentencing agreement.
A presentence investigation (PSI) was prepared; Adams was 20 at the time, had no prior criminal history, two young children, limited education and sporadic employment.
On June 28, 2019, the trial court sentenced Adams to nine years at hard labor; Adams filed a motion to reconsider based on youth and lack of record, which was denied without a hearing.
Adams appealed, arguing the nine-year sentence was excessive given his age, lack of criminal history, remorse, and that the act was impulsive and unlikely to recur.

Issue	State's Argument	Adams's Argument	Held
Whether the nine-year sentence is excessive/constitutionally disproportionate	Sentence is appropriate; trial court balanced factors and public safety concerns	Sentence is excessive for a youthful, first offender; 5–7 years would be supported by similar cases	Affirmed: nine years is not grossly disproportionate and does not shock the sense of justice
Whether the trial court adequately considered La. C. Cr. P. art. 894.1 factors	Record and judge's reasons show adequate consideration of sentencing criteria	Trial court failed to give mitigating weight to youth/remorse	Affirmed: even without reciting every factor, the record and reasons supply an adequate factual basis
Effect of plea benefit and original charge on sentencing discretion	Plea gave substantial benefit; that reduction supports trial court's discretion to impose a mid/upper-range sentence	Adams argues youth and lack of record should outweigh plea benefit	Held for State: plea reduction from attempted murder to battery justified broad sentencing discretion, including midrange sentence

State v. Smith, 433 So. 2d 688 (La. 1983) (trial court need not list every art. 894.1 factor; record must reflect adequate consideration)
State v. Lanclos, 419 So. 2d 475 (La. 1982) (adequate factual basis in record can obviate remand for stricter art. 894.1 compliance)
State v. Dorthey, 623 So. 2d 1276 (La. 1993) (constitutional excessiveness standard: sentence cannot be grossly out of proportion)
State v. Bonanno, 384 So. 2d 355 (La. 1980) (same; purposeless and needless infliction of pain standard)
State v. Williams, 893 So. 2d 7 (La. 2004) (trial court has wide sentencing discretion within statutory limits)
State v. Givens, 42 So. 3d 451 (La. App. 2 Cir. 2010) (plea bargains that substantially reduce exposure are a legitimate sentencing consideration)
State v. Mendenhall, 115 So. 3d 727 (La. App. 2 Cir. 2013) (same: plea benefit relevant to sentencing discretion)
State v. DeBerry, 194 So. 3d 657 (La. App. 2 Cir. 2016) (discussing factors to be considered under art. 894.1 and appellate review scope)