State v. Williams, 199 So. 3d 1205

On June 19, 2014 police observed a hand-to-hand narcotics transaction; the rear passenger (Torrian Veal) discarded plastic bags containing crack cocaine during a vehicle flight; Veal was arrested and drugs and cash were recovered.
Detectives observed and later identified Kerwin Williams as the driver of the silver Pontiac involved; traffic tickets bearing Williams's name were found in the vehicle.
Williams was charged as a principal to possession with intent to distribute cocaine; after a bench trial he was convicted, sentenced, and then adjudicated a second felony offender, which produced an enhanced sentence.
Williams appealed, raising (1) insufficiency of the evidence (misidentification and lack of proof he was a principal) and (2) that his prior guilty plea (predicate for the multiple-offender bill) was constitutionally invalid because the Boykin colloquy addressed multiple defendants at once.
The district court found the officers' identifications credible, concluded Williams knowingly facilitated the drug transaction as driver/getaway driver (hence a principal), and denied the motion to quash the multiple-offender bill after finding the prior plea was knowingly and voluntarily entered.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of the evidence to convict Williams as a principal to possession with intent to distribute cocaine	State: Officers positively identified Williams as the driver; facts show he transported, facilitated, and fled with the seller — supporting principal liability and intent to distribute	Williams: Misidentification by police; insufficient evidence he knowingly participated or had intent to distribute	Court: Affirmed — officers' identification credited; as driver/getaway he knowingly facilitated the transaction, so evidence sufficient to convict as a principal
Validity of predicate guilty plea for multiple-offender adjudication	State: Introduced transcript, commitment, and waiver-of-rights form showing counsel and a proper Boykin colloquy	Williams: Plea unconstitutional because the court addressed multiple defendants collectively during the Boykin colloquy	Court: Affirmed — transcript shows individual colloquies and explicit waivers; plea was knowing and voluntary, so motion to quash properly denied

Jackson v. Virginia, 443 U.S. 307 (U.S. 1979) (standard for reviewing sufficiency of the evidence)
State v. Shelton, 621 So.2d 769 (La. 1993) (framework for challenging predicate guilty pleas in multiple‑offender proceedings)
State v. Hearold, 603 So.2d 731 (La. 1992) (sequence for addressing sufficiency before trial errors on appeal)
State v. Trahan, 425 So.2d 1222 (La. 1983) (definitions and distinctions of actual and constructive possession)
State v. Celestine, 671 So.2d 896 (La. 1996) (application of principals law to narcotics distribution)