State v. Stokes

Citation: 255 So. 3d 1163Docket: 17-970

Court: Louisiana Court of Appeal; September 26, 2018; Louisiana; State Appellate Court

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On April 5, 2007, Ruffin Stokes was charged with armed robbery under La.R.S. 14:64 and found guilty by a jury on February 8, 2010. He was sentenced to seventy-five years at hard labor without parole, probation, or suspension of sentence on April 19, 2010. Stokes filed a pro se Motion to Reconsider Sentence, followed by a motion from his defense counsel on May 21, 2010, to reconsider or appeal. The trial court denied these motions after a hearing on July 30, 2010. In 2016, Stokes sought a status conference on his unperfected appeal and was granted an out-of-time appeal on August 10, 2016, without objection from the State.

On appeal, Stokes argued that his sentence was constitutionally excessive, claiming the trial court failed to adequately consider mitigating factors and tailor the sentence appropriately. The uncontested facts revealed that Stokes participated in a violent robbery where he threatened a child, leading to a struggle that discharged a firearm. The court referenced the standard for reviewing excessive sentence claims, emphasizing that a sentence can be deemed excessive if it is grossly disproportionate to the crime or serves no meaningful penal purpose. The trial court has broad discretion in sentencing, which will not be overturned unless there is a manifest abuse of discretion. Ultimately, the court vacated Stokes' sentence and remanded the case for resentencing.

Sentences for crimes must be tailored to the individual offender and the specific offense, with trial judges best positioned to evaluate aggravating and mitigating factors. While a judge is not required to detail every circumstance listed under art. 894.1, the record must demonstrate that these factors were adequately considered. Maximum sentences should be reserved for the most serious offenses and offenders. In the current case, the defendant was convicted of armed robbery, which under Louisiana law mandates a sentence of 10 to 99 years without parole, probation, or suspension. The defendant argues that his sentence of 75 years is excessive, claiming the trial court failed to consider his youth and first-time offender status as mitigating factors. Instead, the court viewed his age as an aggravating element, suggesting he was likely to reoffend. The trial court acknowledged the seriousness of the crime, emphasizing the defendant's use of a weapon and the threat posed to victims, including a child. The defendant's request for resentencing is based on the assertion that his circumstances do not align with the profile of the worst offenders for whom maximum sentences are intended.

Victim Impact Statements reveal the significant impact of the crime on victims, leading to the conclusion that Mr. Stokes warrants a severe penalty. The Court imposes a sentence of seventy-five years at hard labor without the possibility of probation, parole, or suspension, citing an undue risk of reoffending during any potential suspension. The Court finds that Mr. Stokes is a serious offender, given his violent actions, which included threatening to shoot a three-year-old child over a financial dispute, thereby placing the child and others in severe danger. The Court deems a lesser sentence inappropriate, as it would undermine the seriousness of the offense, characterized as particularly heinous with a high potential for fatality. 

The document references previous cases where sentences for armed robbery exceeded minimums despite the defendants' youth or first-time offender status, particularly when circumstances were egregious. Sentences upheld in similar cases included sixty years for a nineteen-year-old with no prior record and seventy years for a twenty-two-year-old with a violent history. The Court emphasizes that the brutality of the crime substantially influences sentencing decisions, consistent with precedents where lengthy sentences were affirmed even for younger, first-time offenders if the crime was exceptionally violent.

The defendant threatened a victim with a gun but did not injure them, discharging the weapon during the encounter. Previous cases referenced include State v. Mitchell, where a young offender received a 50-year sentence for a violent robbery, and State v. Smith, which involved a 60-year sentence for armed robbery with a substantial criminal history. In the current case, the sentencing court disregarded evidence of the defendant's involvement in prior armed robberies due to insufficient clarity, despite a three-day crime spree that fortunately resulted in no fatalities. Typically, sentences for similar offenses without prior criminal history and no weapon discharge range from 20 to 40 years. In cited cases like State v. Price, a 40-year sentence was deemed appropriate for armed robbery without shots fired. The trial court imposed a 60-year concurrent sentence for nine armed robbery counts, consistent with statutory guidelines (5 to 99 years). The appeal centers on whether the trial court abused its discretion, evaluated through the nature of the crime, the offender's background, and similar sentencing. The review concluded that the 60-year sentence, while above the usual range for first-time offenders, is justified given the violent nature of the defendant's actions and falls within the legal parameters established.

The defendant, Ruffin Stokes, was involved in an armed robbery during which two victims, Adriene Bazile and Laura Waguespack, testified that they were threatened with a gun, instilling fear for their lives. Bazile described being terrified and collapsing on the floor post-robbery, while Waguespack expressed her nervousness during the incident. The court found Stokes' seventy-five-year sentence for armed robbery to be constitutionally excessive, particularly because he was a first-time felony offender, only nineteen at the time of the crime, and did not fire a weapon during the robbery. The court referenced a precedent where a lengthy sentence for a juvenile offender was deemed excessive, emphasizing that Stokes’ juvenile record largely consisted of escape incidents and that this robbery was his first violent crime. The Second Circuit deemed that a more appropriate maximum sentence would be 35 years without benefits. Consequently, the court vacated Stokes' sentence, deeming it an abuse of discretion, and remanded the case for resentencing, noting that no further evidence was presented during the reconsideration hearing.