State v. Mayfield

Citation: 261 So. 3d 101Docket: 18-420

Court: Louisiana Court of Appeal; December 5, 2018; Louisiana; State Appellate Court

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Defendant Marlin L. Mayfield pleaded guilty to manslaughter and aggravated assault with a firearm following the June 23, 2013, shooting of his wife, Teresa Mayfield, during a domestic dispute. After initially being indicted for first-degree murder and second-degree kidnapping, he changed his plea to guilty on October 16, 2013. At sentencing, on October 12, 2017, the trial court imposed a forty-year sentence for manslaughter, without the possibility of parole, probation, or suspension, and a consecutive seven-year sentence for aggravated assault. Mayfield filed a motion to reconsider his sentence, claiming it was excessively harsh and that mitigating factors were not considered, but the trial court denied this motion.

On appeal, Mayfield contended that his manslaughter sentence was excessive. The appellate court conducted a review for errors patent and identified two issues. First, the court found that the trial court improperly mandated that the manslaughter sentence be served without the benefit of parole, as Louisiana law does not prohibit parole for this offense. However, it affirmed that the trial court correctly imposed the sentence without the benefit of probation or suspension, in line with the applicable laws concerning crimes of violence. Thus, while the appellate court amended the sentencing order to allow for parole eligibility on the manslaughter charge, it upheld the overall sentence as amended.

The court amends the Defendant's manslaughter sentence to remove the denial of parole eligibility and directs the district court to update the minutes accordingly. It notes that although the sentence is indicated to be served at hard labor, the trial court did not impose it as such during the sentencing hearing, which renders the sentence illegally lenient. The court clarifies that it will not review an illegally lenient sentence unless specifically raised on appeal. 

The Defendant claims the trial court erred by imposing the maximum forty-year sentence for manslaughter without considering mitigating factors such as his mental health history, military service, and lack of prior criminal history. He argues that the sentence is excessive and is divided into two parts: the failure to consider mitigating factors and the excessive nature of the forty-year maximum sentence. 

The court emphasizes the standard of review for excessive sentence claims, citing Louisiana's constitutional provision against cruel or unusual punishment. An excessive sentence is defined as one that is grossly disproportionate to the crime or fails to contribute meaningfully to penal goals, leading to unnecessary suffering. The trial court has broad discretion in sentencing, and a sentence will not be overturned unless there is a manifest abuse of that discretion. 

Factors for determining whether a sentence is shocking or unreasonably excessive include the nature of the offense, the offender's circumstances, the legislative intent behind the penalty, and comparisons to sentences for similar crimes. However, sentences should be individualized, and the trial court is best positioned to assess the relevant circumstances. While not required to detail every mitigating factor, the trial judge must demonstrate that they adequately considered the guidelines when determining the sentence.

In State v. Smith, the appellate court upheld that a sentence cannot be overturned for excessiveness if there is sufficient record support (La.Code Crim. P. art. 881.4(D)). Maximum sentences are typically reserved for the most severe offenders and offenses. Prior to sentencing, Defendant submitted a comprehensive memorandum reviewed by the trial court, detailing personal history and mitigating factors, including military service records, a psychologist's evaluation, and numerous letters of support from the community. The memorandum also highlighted a prior incident where Defendant threatened Mrs. Mayfield with a gun, leading to a mental health evaluation during which he was diagnosed with severe depression and psychosis. Witness testimonies at the sentencing hearing included that of Terrance Martin, who described Defendant as a well-behaved, active child and a supportive friend, expressing shock over the crime. Martin emphasized Defendant's remorse and efforts to mentor inmates in prison but acknowledged that Defendant left mental health treatment prematurely. Chris Mayfield, Defendant's brother, corroborated the close family bond, Defendant's military pride, and his devastation over family losses. He also testified to Defendant's remorse and awareness of the restraining order obtained by Mrs. Mayfield, stating she was not violent and referenced allegations of abuse against their daughter.

Defendant's children had limited contact with him during his incarceration and were present at the residence when he killed his wife. Testimony from Chris Mayfield indicated that one child was at home during the incident. The State presented a victim impact statement from Mrs. Mayfield's sister, arguing for the maximum sentence for Defendant, who pled guilty to manslaughter after initially facing first-degree murder charges. The State emphasized the severity of the crime, where Defendant shot his wife in the back of the head while their children were nearby.

Defense counsel contended that Defendant accepted responsibility and presented mitigating factors, including his lack of criminal history, medical issues treated at a mental health facility, potential for rehabilitation, and his service in the military. The trial court considered these factors, along with extensive testimony, community support letters, and a presentence investigation (PSI) report.

The court noted that the facts of the case suggested a minimum of second-degree murder, which could result in a life sentence, and deemed the Defendant's actions heinous. The plea to manslaughter was viewed as leniency. On appeal, Defendant argued that his actions were less cruel than those in other cases where maximum sentences were imposed. The court referenced State v. Plauche, where a defendant received a forty-year sentence for a similar crime, and State v. Soriano, which involved a stabbing case with a first-time offender receiving a maximum sentence. The trial court found no abuse of discretion in sentencing Defendant to the maximum for manslaughter, highlighting the seriousness of his conduct.

The trial court denied the defendant's self-defense argument, noting a lack of explanation for why he pursued and stabbed the victim a second time instead of retreating. In the case of State v. Duhon, the court upheld a maximum manslaughter sentence for a defendant who shot three relatives of his wife, called 911, retrieved his son, and fled when confronted by a woman believing he was attempting to steal her car. He was charged with two counts of attempted first-degree murder and one count of first-degree murder but pled guilty to manslaughter and attempted manslaughter. Testimonies revealed the defendant had a history of violence, including strangling his wife, and suffered from flashbacks due to a dishonorable military discharge related to drug use. Despite expert opinions on his mental state, the court affirmed the maximum sentence.

In contrast, in Frazier, a mid-range sentence of twenty years was affirmed for a fatal stabbing after a parking dispute, considering the defendant's remorse and character. Similarly, in State v. Osborn, a thirty-year sentence was upheld for a manslaughter plea involving a bar altercation where the defendant shot a victim while attempting to stop a fight, with the court weighing his age and character. The current case was deemed more severe; the defendant shot his wife in the head in front of their child, had prior incidents of violence, and was under a restraining order for domestic abuse. Although he expressed remorse and turned himself in, the trial court found his actions indicative of second-degree murder, highlighting that without a plea deal, he could have faced a life sentence. The court considered all mitigating factors before determining the defendant's sentence.

Defendant's actions are characterized as particularly egregious, comparable to previous cases that warranted maximum sentences for manslaughter. The trial court's decision to impose a forty-year maximum sentence for manslaughter is upheld, although the denial of parole eligibility is reversed, and the district court is instructed to record this amendment. The analysis relies on the sentencing memorandum and pre-sentence investigation report due to insufficient factual details presented during the plea and sentencing hearings. The trial court did not explicitly identify the seven-year sentence as related to aggravated assault with a firearm; however, it is evident from the transcript that this sentence is linked to La.R.S. 14:37.4, which caps the sentence at seven years. Consequently, no error is found in this context. The applicable version of Louisiana Code of Criminal Procedure article 893, which has undergone multiple amendments, is the one in effect at the time of the offense, confirming that the Defendant remains ineligible for probation or sentence suspension. The State’s prior decision not to pursue the death penalty means Defendant faced life imprisonment for the first-degree murder charge.