People v. Loeffler CA4/1, D084199

Sean Loeffler pled guilty to two counts of making criminal threats and one count of corporal injury to an intimate partner; he also admitted to a probation violation in a separate case.
In exchange for the guilty plea, other charges were dismissed.
Loeffler was sentenced to two years in prison and was subject to ten-year protective orders regarding five victims.
Loeffler timely appealed the judgment but did not obtain a certificate of probable cause.
His appointed counsel filed a Wende brief stating there were no arguable issues for appeal; Loeffler submitted a supplemental pro per brief.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Validity of protective order for uncharged victim	Protective order necessary for victim safety	Order improper because not convicted for that victim	Affirmed; order permitted by statute
Entitlement to an Alford plea (pleading guilty while innocent)	N/A	Should be allowed an Alford plea	Not cognizable on appeal; forfeited

People v. Wende, 25 Cal.3d 436 (Cal. 1979) (provides procedure for appellate review when counsel finds no arguable issues)
Anders v. California, 386 U.S. 738 (1967) (establishes requirements for appellate counsel in no-merit appeals)
North Carolina v. Alford, 400 U.S. 25 (1970) (permits defendants to plead guilty without admitting guilt)