State v. Williams, 81 So. 3d 908

Williams was charged by information with two counts of armed robbery under La. Rev. Stat. 14:64.
Trial occurred June–July 2010 before a 12-person jury that found Williams guilty on both counts.
Sentencing on September 17, 2010 imposed 25 years for each count, to run concurrently.
Williams filed a timely motion for a new trial on July 23, 2010.
The trial court did not dispose of the motion before sentencing, and a handwritten note indicated a pending en banc order; on appeal, the court vacated the sentences and remanded for a ruling on the new-trial motion, preserving Williams's right to appeal if the motion was denied.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the jury instruction allowed conviction by less than unanimous verdict for a hard-labor offense	Williams argues error in allowing less than unanimous verdicts.	Williams asserts inconsistent verdict and non-unanimity undermining due process.	Resolution reserved; this issue is subsumed by remand procedure.
Whether the sentences were excessive	Williams contends sentences were excessive.	Not explicitly stated; challenge to sentencing.	Pretermitted; remand for ruling on new trial before addressing merits.
Whether the trial court erred by failing to rule on the timely motion for a new trial	Motion for new trial timely filed; merits unknown due to lack of ruling.	No ruling presented in record.	Error patent; vacate sentences and remand to rule on the motion for new trial with right to appeal if unfavorable.

State v. Randolph, 409 So.2d 554 (La. 1981) (per curiam; guide on motions for new trial and post-verdict judgments)
State v. Williams, 30 So.3d 975 (La. App. 5 Cir. 2009) (failure to rule on motion for new trial requires remand)
State v. Pettus, 66 So.3d 1192 (La. App. 5 Cir. 2011) (remand for rulings on motions while preserving appeal rights)
State v. Falcon, 956 So.2d 650 (La. App. 5 Cir. 2007) (error patent when trial court fails to rule on new-trial motion)