State v. Williams, 245 So. 3d 131

Ladarius Williams pled guilty to attempted first-degree murder with a firearm enhancement after surveillance video and eyewitness identification linked him to a brutal street robbery/shooting that left the victim with multiple gunshot wounds and long-term injuries.
Williams admitted guilt as trial had begun; the state agreed not to file a habitual-offender (multiple offender) bill and dismissed other pending charges in exchange for the plea.
He was sentenced to the statutory maximum: 50 years at hard labor without parole, probation, or suspension of sentence; a motion to reconsider on excessiveness grounds was denied.
Williams challenged the sentence on appeal as excessive, arguing his youth and limited serious adult record made him less than the "worst offender."
The State argued the sentence was appropriate given the crime's brutality, Williams' criminal history and lack of remorse, his benefit from the plea bargain, and public-safety concerns.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the 50-year sentence is constitutionally excessive	Williams: sentence is excessive given youth and lack of serious adult record	State: crime brutality, prior record, lack of remorse, and plea benefit justify sentence	Affirmed — sentence not grossly disproportionate; no abuse of discretion
Whether trial court had to give age particular weight	Williams: youth should warrant leniency	State: mitigating weight is discretionary	Held: court considered age; no required weight and it was outweighed by aggravation
Whether plea bargain (avoiding habitual-offender exposure) affects sentencing discretion	Williams: received benefit but argues lesser sentence still warranted	State: plea benefit supports harsher sentence within statutory range	Held: plea benefit is relevant; trial court may impose maximum when defendant avoided greater exposure
Whether record shows trial-court sentencing error patent	Williams: raised only constitutional excessiveness on reconsideration	State: no patent error	Held: no error patent found on review

State v. Dorthey, 623 So.2d 1276 (La. 1993) (sets constitutional excessiveness standard)
State v. Griffin, 180 So.3d 1262 (La. 2015) (factors for assessing excessive sentence and test for gross disproportionality)
State v. Fruge, 179 So.3d 579 (La. 2015) (trial court discretion and factors for sentence review)
State v. Washington, 185 So.3d 852 (La. App. 2 Cir. 2016) (discusses when maximum sentences are appropriate after plea bargains)
State v. Brisco, 933 So.2d 754 (La. 2006) (discretion to apply firearm-discharge enhancement when firearm use is an element)
State v. Cotten, 438 So.2d 1156 (La. App. 1 Cir. 1983) (upholding maximum sentence in attempted murder involving close-range shooting)
State v. Lyles, 483 So.2d 1174 (La. App. 4 Cir. 1986) (upholding maximum sentence for multiple close-range shootings)
State v. Hughes, 165 So.3d 978 (La. App. 5 Cir. 2014) (upholding maximum sentence where defendant fired at close range and pursued victim)
State v. Stacker, 836 So.2d 601 (La. App. 5 Cir. 2002) (upholding maximum sentence for close-range shooting that endangered others)