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STATE EX REL. WILLIAMS v. State

Citations: 999 So. 2d 1136; 2009 La. LEXIS 24; 2009 WL 279869Docket: 2008-KH-1059

Court: Supreme Court of Louisiana; February 5, 2009; Louisiana; State Supreme Court

Narrative Opinion Summary

The Supreme Court of Louisiana granted a request for review in the case of STATE ex rel. Charles WILLIAMS v. STATE of Louisiana, finding that the trial judge lacked the authority to suspend Williams' manslaughter sentence and place him on probation. Consequently, the court of appeal vacated the sentence and remanded the case for resentencing in line with Louisiana Code of Criminal Procedure article 893(A), and relevant state statutes. The court of appeal denied Williams' request for a new trial, but the plea colloquy transcript indicated that all parties believed Williams would receive a suspended sentence and probation upon his guilty plea. Therefore, prior to resentencing, the district court is required to offer Williams the chance to withdraw his guilty plea and enter a new plea. This decision aligns with precedent indicating that a plea may be withdrawn if it was based on a mutual misunderstanding regarding the trial judge's sentencing authority.

Legal Issues Addressed

Authority of Trial Judge in Sentencing

Application: The trial judge did not have the authority to suspend the sentence for manslaughter and place the defendant on probation.

Reasoning: The Supreme Court of Louisiana granted a request for review in the case of STATE ex rel. Charles WILLIAMS v. STATE of Louisiana, finding that the trial judge lacked the authority to suspend Williams' manslaughter sentence and place him on probation.

Precedent on Plea Withdrawal

Application: The decision to allow withdrawal of the plea aligns with established precedent regarding misunderstandings in plea agreements.

Reasoning: This decision aligns with precedent indicating that a plea may be withdrawn if it was based on a mutual misunderstanding regarding the trial judge's sentencing authority.

Resentencing Procedure

Application: The case was remanded for resentencing in accordance with the correct legal procedures under Louisiana Code of Criminal Procedure article 893(A).

Reasoning: Consequently, the court of appeal vacated the sentence and remanded the case for resentencing in line with Louisiana Code of Criminal Procedure article 893(A), and relevant state statutes.

Withdrawal of Guilty Plea

Application: The defendant must be allowed to withdraw his guilty plea if it was based on a mutual misunderstanding of the sentencing authority.

Reasoning: Therefore, prior to resentencing, the district court is required to offer Williams the chance to withdraw his guilty plea and enter a new plea.