State v. Williams, 128 So. 3d 1250

Defendant Kenyetta Denise Williams (age 16 at offense) was linked to the homicide of Marvin Aguilar Osario and arrested after using the victim’s cell phone; she confessed after being Mirandized and questioned without a guardian present.
Victim died of multiple stab wounds; Williams and an accomplice had been engaged in prostitution with the victim and robbed him (cell phone, handgun, money).
Williams was indicted for second-degree murder; sanity evaluation found her competent and not legally insane.
By plea agreement Williams pled guilty to attempted manslaughter (maximum 20 years) after Boykin colloquy acknowledging possible 20-year sentence; court ordered PSI.
Sentenced to 20 years at hard labor; motion to reconsider (arguing victim’s conduct and her youth) denied.
On appeal Williams argued the sentence was excessive; the court affirmed conviction and 20-year sentence.

Issue	Williams' Argument	State's Argument	Held
Whether 20-year sentence is excessive	20 years (maximum) not warranted; she is not a worst offender; mitigating factors (teenage, homeless, prostitution, rehabilitation)	Trial court properly considered factors, plea reduced exposure from murder to attempted manslaughter, violence and death aggravated sentence	Affirmed: sentence not constitutionally excessive; court acted within discretion
Whether trial court complied with La. C. Cr. P. art. 894.1	Court failed to adequately consider mitigating factors	Court complied: ordered PSI, considered personal history, mitigating and aggravating factors	Affirmed: record shows cognizance of 894.1 criteria
Whether sentence is grossly disproportionate under La. Const. art. I, § 20	20-year term shocks the sense of justice given circumstances	Sentence proportional to harm (death during planned robbery) and defendant received plea-leniency	Affirmed: not grossly disproportionate
Whether plea bargaining justified significant reduction from murder exposure	N/A (argument focused on excessiveness)	Plea reduced exposure from mandatory life for 2nd-degree murder to max 20 years; court may impose max when plea charge understates conduct	Affirmed: trial court within discretion to impose maximum for plea offense

State v. Elmore, 80 So.3d 731 (La. App. 2011) (art. 894.1’s goal is factual articulation, not rigid checklist)
State v. Jones, 398 So.2d 1049 (La. 1981) (factors to consider at sentencing: personal history, prior record, seriousness, rehabilitation)
State v. Haley, 873 So.2d 747 (La. App. 2004) (sentencing review standards)
State v. McKinney, 976 So.2d 802 (La. App. 2008) (court may impose maximum where plea reduces exposure and plea offense understates conduct)
State v. Williams, 893 So.2d 7 (La. 2004) (wide trial court discretion in sentencing; appellate review for abuse only)
State v. Smith, 839 So.2d 1 (La. 2003) (constitutional prohibition on grossly disproportionate sentences)
State v. Weaver, 805 So.2d 166 (La. 2002) (gross disproportionality standard: shocks sense of justice)