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State v. Spruell

Supreme Court of Louisiana
Sep 2, 1981
403 So. 2d 63 (La. 1981)

Summary

In State v. Spruell, 403 So.2d 63 (La.1981), the defendant pled guilty to possession of marijuana with intent to distribute and was sentenced to five years in prison.

Summary of this case from State v. Swafford

Opinion

No. 81-KA-0304.

September 2, 1981.

APPEAL FROM 28TH JUDICIAL DISTRICT COURT, PARISH OF LaSALLE, STATE OF LOUISIANA, HONORABLE EDWIN R. HUGHES, J.

William J. Guste, Jr., Atty. Gen., Barbara Rutledge, Asst. Atty. Gen., Speedy O. Long, Dist. Atty., Dan B. Cornett, Asst. Dist. Atty., for plaintiff-appellee.

Patrick L. Durusau, Jena, Howard N. Nugent, Jr., Ford Nugent, Alexandria, for defendant-appellant.


On January 3, 1980, defendant Roy L. Spruell was charged by bill of information with possession of marijuana with intent to distribute, in violation of La.R.S. 40:967. The trial court subsequently accepted defendant's plea of guilty and, on December 8, 1980, sentenced him to five years' imprisonment at hard labor. By this appeal, defendant urges that the trial court erred in utilizing the wrong penalty provisions during sentencing and in failing to justify an apparently severe sentence according to the sentencing guidelines set forth in La.C.Cr.P. Art. 894.1. We agree with the defendant and, accordingly, remand this case to the trial court for resentencing.

Although defendant did not object at the time of sentencing that the trial court had not complied with Art. 894.1, or that the sentence imposed was excessive, we have held that this failing will not bar later review of either complaint. State v. Smith, 389 So.2d 1262 (La. 1980); State v. Bourgeois, 388 So.2d 359 (La. 1980); State v. Cox, 369 So.2d 118 (La. 1979).

Before imposing sentence herein, the trial court referred only to defendant's record. It noted that, in addition to a conviction of receiving stolen things in 1976, defendant presently faced additional counts of simple burglary and receiving stolen things, charges which arose while the accused was on bond for the instant offense. Defendant made no effort to deny these allegations and, when offered an opportunity to address the court, had nothing to say. Immediately thereafter, the trial court sentenced the accused to five years at hard labor, a sentence which the trial court felt to be the minimum allowable under R.S. 40:967.

In reality, the cited penal provision, R.S. 40:967(B)(1), deals only with the intended distribution of Schedule II narcotics, see R.S. 40:964, a classification not including marijuana, the distribution of which carries no minimum penalty and a maximum of ten rather than thirty years' imprisonment. Though the sentence actually imposed fell within the statutorily-prescribed range, the danger that such a mistake of law might have affected the trial court's attempt at leniency appears significant. For this reason, a sentence founded on an incorrect view of the law should usually be set aside. See, State v. Battaglia, 377 So.2d 264 (La. 1979); ABA Standards of Criminal Justice (2d ed. 1980), § 20-3.2(b) and commentary at p. 20-30.

The trial court's mistaken view of the statutorily authorized penalty also resulted in its unknowing imposition of a relatively stiff sentence rather than a minimal one. The imposition of such an apparently severe sentence requires record justification by the trial court, whose responsibility it is to ensure that the sentence has a sufficient informational basis to protect the accused's right of review on appeal. La.C.Cr.P. Art. 894.1(C); State v. Sepulvado, 359 So.2d 137 (La. 1978). Such factual justification is especially crucial where, as here, the accused's guilty plea leaves no other evidence of record which clearly illumines the trial court's sentencing choice. See, State v. Martin, 400 So.2d 1063 (La. 1981) (on rehearing).

In the present case, the mere mention of defendant's criminal record was insufficient to satisfy Article 894.1's mandate that the sentence be individualized to both the offense and the offender. State v. Jones, 398 So.2d 1049 (La. 1981). While the trial judge need not articulate every aggravating and mitigating circumstance enumerated under Article 894.1, the record must reflect that it adequately considered these guidelines in particularizing the sentence to the accused. State v. Guiden, 399 So.2d 194 (La. 1981). Absent such consideration, we lack appropriate criteria by which to measure whether this sentence is excessive under our state constitution. State v. Smith, supra; State v. Dye, 384 So.2d 420 (La. 1980); State v. Kenner, 384 So.2d 413 (La. 1980).

Accordingly, we affirm defendant's conviction but vacate the sentence imposed and remand the case for resentencing in accordance with law.

CONVICTION AFFIRMED; SENTENCE VACATED AND CASE REMANDED.


Summaries of

State v. Spruell

Supreme Court of Louisiana
Sep 2, 1981
403 So. 2d 63 (La. 1981)

In State v. Spruell, 403 So.2d 63 (La.1981), the defendant pled guilty to possession of marijuana with intent to distribute and was sentenced to five years in prison.

Summary of this case from State v. Swafford

In State v. Spruell, 403 So.2d 63 (La.1981), the defendant pled guilty to possession of marijuana with intent to distribute and was sentenced to five years in prison.

Summary of this case from State v. Green

In State v. Spruell, 403 So.2d 63 (La.1981), a trial court had mistakenly looked at the sentencing range for cocaine distribution (two to 30 years) when it should have looked at the sentencing range for marijuana distribution (zero to 10 years).

Summary of this case from State v. Davis

In State v. Spruell, 403 So.2d 63 (La.1981), the defendant pled guilty to possession of marijuana with intent to distribute and was sentenced to five years in prison.

Summary of this case from State v. Preston

In Spruell, the defendant apparently pleaded guilty without a definite understanding as to the sentence that would be imposed.

Summary of this case from State v. Blanchard

In State v. Spruell, 403 So.2d 63 (La. 1981), the Supreme Court held that defendant's sentence of five years at hard labor was to be vacated due to the trial court's mistaken view of the statutorily-authorized penalty, resulting in its unknowing imposition of a relatively stiff sentence rather than a minimal one, and because the trial court's mere mention of defendant's criminal record was insufficient to satisfy the statutory mandate of LSA-C.Cr.P. art. 894.1.

Summary of this case from State v. Blanchard
Case details for

State v. Spruell

Case Details

Full title:STATE OF LOUISIANA v. ROY L. SPRUELL

Court:Supreme Court of Louisiana

Date published: Sep 2, 1981

Citations

403 So. 2d 63 (La. 1981)

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State v. Green

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