State v. Young, 73 So. 3d 473

Young pled guilty to failure to register as a sex offender, second offense, under La. R.S. 15:542.1.4 and was sentenced to 20 years hard labor without probation, parole, or suspension to run consecutively.
The PSC noted a long criminal history including prior sex-offender convictions and other felonies dating back to 1982, with repeated violations of supervision and parole.
At plea, Young disputed the recited facts; the court amended the charge to second offense with no sentence stipulation, and a guilty plea was accepted.
Young admitted limited compliance with registration and notification due to lack of funds for notice obligations.
The trial court relied on Young’s repeated violations and flight from supervision to justify the maximum sentence, rejecting any probated sentence.
An error patent issue arose: the court failed to impose the mandatory $3,000 fine; the court declined to correct this and affirmed the sentence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the 20-year sentence is constitutionally excessive	Young argues the term is grossly disproportionate given lack of intent and circumstances.	State contends the sentence fits the defendant’s history and the offense’s seriousness, within discretion.	No; sentence within statutory limits and not grossly disproportionate given history.
Whether the trial court abused its discretion in sentencing	Young claims lesser sentence would suffice due to non-violent scope and plea context.	State asserts trial court properly weighed prior offenses and risk of flight to tailor punishment.	No; discretion within statutory range and supported by history and risk factors.
Whether disproportionate sentence is mandated by Eighth Amendment given plea to second offense	Young contends plea and lack of intent negate the harsh punishment.	State argues Eighth Amendment challenge is constrained by legislatively defined punishment.	No; Eighth Amendment challenge rejected given statutory framework and defendant’s history.

State v. Dorthey, 623 So.2d 1276 (La. 1993) (gross disproportionality standard for excessive sentences under La. Const. art. 1, § 20)
State v. Smith, 839 So.2d 1 (La. 2003) (gross disproportionality and abuse-of-discretion principles)
State v. Weaver, 805 So.2d 166 (La. 2002) (gross disproportionality framework in assessing sentences)
State v. Lobato, 603 So.2d 739 (La. 1992) (shock-the-conscience proportionality considerations)
State v. Givens, 42 So.3d 451 (La. App. 2 Cir. 2010) (great discretion in plea-bargained maximums for serious offenses)
State v. Guzman, 769 So.2d 1158 (La. 2000) (criteria for reviewing excessiveness; deference to trial court)
State v. June, 873 So.2d 939 (La. App. 2 Cir. 2004) (approval of broad sentencing discretion within statutory limits)
State v. McKinney, 976 So.2d 802 (La. App. 2 Cir. 2008) (maximum sentences and plea context considerations)
State v. Woods, 942 So.2d 658 (La. App. 2 Cir. 2006) (context of appellate review of sentences)
State v. Black, 669 So.2d 430 (La. 1996) (limits on appellate reversal of sentences)