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State v. Jones

Citations: 184 So. 3d 668; 2015 La. LEXIS 2554; 2015 WL 8224125Docket: No. 2015-KK-1723

Court: Supreme Court of Louisiana; December 3, 2015; Louisiana; State Supreme Court

Narrative Opinion Summary

Writ of Certiorari was granted concerning a conviction for the misdemeanor of Contributing to the Delinquency of Minors under La. R.S. 14:92 A(2). The trial court found the defendant guilty but failed to provide reasons for imposing the maximum sentence of six months in jail. This lack of explanation was deemed inconsistent with the requirements of La.C.Cr. P. art. 894.1, which mandates that courts articulate reasons for sentencing. Consequently, the defendant's sentence was set aside, and the case was remanded to the trial court for resentencing, ensuring compliance with the guidelines outlined in art. 894.1. Chief Justice Johnson dissented, indicating a preference to deny the writ.

Legal Issues Addressed

Judicial Dissent

Application: A dissenting opinion may express disagreement with the majority's decision to grant a writ, as seen when a justice prefers an alternative resolution.

Reasoning: Chief Justice Johnson dissented, indicating a preference to deny the writ.

Remand for Resentencing

Application: When a trial court fails to comply with sentencing guidelines, the appropriate remedy is to set aside the sentence and remand the case for resentencing.

Reasoning: Consequently, the defendant's sentence was set aside, and the case was remanded to the trial court for resentencing, ensuring compliance with the guidelines outlined in art. 894.1.

Sentencing Requirements under La.C.Cr. P. art. 894.1

Application: The trial court is required to articulate specific reasons for imposing a sentence, especially when the maximum penalty is applied.

Reasoning: The trial court found the defendant guilty but failed to provide reasons for imposing the maximum sentence of six months in jail. This lack of explanation was deemed inconsistent with the requirements of La.C.Cr. P. art. 894.1, which mandates that courts articulate reasons for sentencing.