State v. Washington, 245 So. 3d 1234

Defendant Tyrone Washington, former stepfather, was tried and convicted by a unanimous jury for molestation of a juvenile (victim M.B.), based on testimony that sexual acts occurred when she was 11.
Police interviewed Washington after a report; he waived Miranda and gave two recorded statements, initially denying then admitting sexual intercourse with M.B. four times. He later moved to suppress the confession.
Victim M.B. and two sisters (A.B., C.B.) testified about observations and threats allegedly made by Washington; the jury credited their testimony over Washington’s denials.
Trial court denied the motion to suppress after hearing Detective Belle’s testimony that no threats, promises, or inducements were made and that Washington appeared oriented; recordings showed coherent waiver and incriminating admissions.
Washington was sentenced to 60 years at hard labor (statutory range 25–99 years) with the first 25 years without benefit of parole/probation/suspension; he argued the sentence was excessive and that mitigating factors (first-felony offender, veteran) were not adequately considered.
The appellate court affirmed: confession admissible, evidence sufficient, and sentence not constitutionally excessive; a presentence investigation was not ordered but the court found Art. 894.1 factors considered.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Washington)	Held
Admissibility of confession	Statement was freely and voluntarily given after Miranda waiver; no threats/promises	Confession coerced by Detective Belle (threats about prior offense, long sentence), defendant under influence of marijuana and had PTSD	Admission proper: waiver valid, audio corroborates orientation, police testimony unrebutted; suppression denial affirmed
Sufficiency of evidence	Victim’s testimony (corroborated by sisters) is sufficient to prove molestation beyond reasonable doubt	Delayed reporting and defendant’s trial denials undermine sufficiency	Evidence sufficient: victim’s testimony and corroboration supported conviction under Jackson standard
Sentence excessive	Midrange sentence appropriate given victim’s age and potential aggravated rape exposure	Sentence excessive given first-felony offender status and military service; PSI absent	Sentence not excessive: court considered Art. 894.1 factors, facts justify midrange 60-year term within statutory limits
Jury instruction (pro se)	Instruction as given misstated law but defense agreed to paragraph; error benefitted defendant	Instruction misstated elements (required both force and influence) and deprived fair instruction	No reversible error: defense agreed, misstatement favored defendant; claim fails

Jackson v. Virginia, 443 U.S. 307 (standard for sufficiency of the evidence)
Miranda v. Arizona, 384 U.S. 436 (custodial warnings required before interrogation)
State v. Blank, 955 So.2d 90 (totality-of-circumstances test for voluntariness of statements)
State v. Lobato, 603 So.2d 739 (remand unnecessary when record shows adequate factual basis for sentence)
State v. Dorthey, 623 So.2d 1276 (constitutional excessiveness standard)
State v. Guzman, 769 So.2d 1158 (sentence grossly disproportionate test)