State v. Woods, 262 So. 3d 455

Corey Woods was convicted by a jury of three counts of distribution of heroin (three controlled buys recorded by an undercover JPSO agent) and later adjudicated a second-felony offender; counts 4–5 were nolle prossed.
Undercover recordings and agent testimony tied Woods to buys on Jan. 10, 17, and 19, 2017; forensic analysts confirmed the seized substances were heroin.
After conviction, Woods initially received 50-year terms on each count to run consecutively; he later stipulated to habitual-offender status and an agreed enhanced 50-year sentence on count one to run consecutively to counts two and three.
Woods appealed, arguing the consecutive 50-year sentences (totaling 150 years) were grossly excessive and that sentencing lacked a pre-sentence investigation and consideration of mitigating factors.
The trial court did not articulate specific reasons for consecutive sentences even though the three convictions arose from a common course of conduct over three days.

Issue	State's Argument	Woods' Argument	Held
Whether Woods may challenge the enhanced (habitual-offender) sentence on appeal	The enhanced sentence was imposed pursuant to an agreement on the record; review is precluded by La. C.Cr.P. art. 881.2	The enhanced consecutive 50-year sentence is grossly excessive	Court: Precluded from review of the enhanced sentence because Woods agreed to it; enhanced sentence affirmed
Whether the consecutive sentences on counts two and three are unconstitutionally excessive	Sentences are within statutory range and reflect legislative concern; no relief warranted	The 50-year consecutive terms (combined into 150 years) are grossly disproportionate given record; lacked PSI and mitigating consideration	Court: Vacated sentences on counts two and three as unconstitutionally excessive; remanded for resentencing
Whether consecutive sentences were justified despite arising from a common scheme over three days	Trial court had discretion to impose consecutive sentences if defendant’s background/acts justified it	Consecutive sentences were not supported by record-specific findings showing worst-type offender or extraordinary facts	Court: Because trial court did not articulate specific reasons for consecutive terms and record was scant, consecutive 150-year exposure shocks the sense of justice

State v. Nguyen, 958 So.2d 61 (La. App. 5 Cir. 2007) (excessive-sentence standard and deference to trial court sentencing discretion)
State v. Lobato, 603 So.2d 739 (La. 1992) (guidance on disproportionality review)
State v. Ortego, 382 So.2d 921 (La. 1980) (concurrent sentences favored where convictions arise from single course of conduct)
State v. Williams, 445 So.2d 1171 (La. 1984) (trial court may impose consecutive sentences where past acts or background justify grave risk to community)
State v. St. Amant, 169 So.3d 535 (La. App. 5 Cir. 2015) (example of concurrent multi-count drug sentences upheld)
State v. Melancon, 151 So.3d 100 (La. App. 5 Cir. 2014) (concurrent sentencing on multiple drug counts affirmed)
State v. Julien, 225 So.3d 1197 (La. App. 5 Cir. 2017) (concurrent lengthy sentence for distribution affirmed)