State v. Stanfield
56 So. 3d 428
La. Ct. App.2011Background
- June 30, 2009, 2–4 a.m., Hays observed two men at the back of 901 Jackson Ave.; defendant identified; an upstairs window air conditioner was missing.
- Hays had an unobstructed view of the defendant’s face in a well-lit area and contacted Mitchell about the burglary.
- The next day, Hays identified the defendant in a photograph during police interviews.
- On Sept. 18, 2009, the State charged the defendant with simple burglary; he pled not guilty; suppression was denied and probable cause found.
- At trial (Feb. 1, 2004), Mitchell, Hays, and Detective Krezemieniecki testified; the State presented eyewitness identification; defendant convicted.
- On March 4, 2010, the trial court sentenced the defendant to 10 years with credit for time served; post-verdict motions were denied and the appeal followed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Excessive sentence for simple burglary | State argues adequate Art. 894.1 basis; parole status and multiple-bill factors justify | Lombard contends the 10-year term is excessive | Not excessive; affirmed |
| Sufficiency of the evidence to support the conviction | Eyewitness identification by Hays suffices to prove burglary | Insufficient evidence to establish guilt beyond a reasonable doubt | Evidence sufficient; conviction affirmed |
Key Cases Cited
- State v. Landry, 871 So.2d 1235 (La.App. 4 Cir. 2004) (excessive-sentence standard and Art. 894.1 considerations)
- State v. Baxley, 656 So.2d 973 (La. 1995) (excessive-punishment standard requires proportionality to offense)
- State v. Francis, 715 So.2d 457 (La.App.4 Cir. 1998) (excessiveness review within constitutional guidelines)
- State v. Johnson, 709 So.2d 672 (La. 1998) (disproportionate punishment standard guiding review)
- State v. Trepagnier, 744 So.2d 181 (La.App. 4 Cir. 1999) (Art. 894.1 compliance and sentencing review framework)
- State v. Lanclos, 419 So.2d 475 (La. 1982) (adequacy of factual basis for sentence without strict compliance)
- State v. Estes, 956 So.2d 779 (La.App.2d Cir. 2007) (admissible sentencing considerations beyond guilt phase)
- State v. Morris, 719 So.2d 1076 (La.App.5 Cir. 1998) (affirming greater sentence for burglary)
- State v. Soraparu, 703 So.2d 608 (La. 1997) (scope of appellate review of sentencing discretion)
- State v. Sepulvado, 367 So.2d 762 (La. 1979) (core principle of proportionality in punishment)