State Of Louisiana v. Jordan Singletary
2021KA1211
| La. Ct. App. | Jun 6, 2022Background
- Defendant Jordan Singletary was charged with molestation of a juvenile but pled guilty at a Boykin hearing to the amended charge of indecent behavior with juveniles (La. R.S. 14:81).
- Prosecutor summarized facts: Singletary babysat victim Sept. 28–30, 2018; the victim’s mother overheard Singletary telling the child to rub his penis; the child reported exposure to pornography and an attempted touch over clothing.
- At sentencing Singletary received seven years at hard labor, with the first two years without parole/probation/suspension; credit for time served; the balance was suspended and he was placed on three years active supervised probation.
- Appellate counsel filed an Anders/Tyles/Benjamin motion to withdraw, asserting a conscientious review found no nonfrivolous appellate issues; Singletary was notified and did not file a pro se brief.
- The court conducted an independent review under La. C.Cr.P. art. 920(2) for patent errors, found none, affirmed the conviction and sentence, and granted counsel’s motion to withdraw.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Validity of guilty plea | Plea was knowingly and voluntarily entered at Boykin colloquy | No nonfrivolous challenge raised | Plea valid; conviction affirmed |
| Sufficiency of factual basis for plea | Prosecutor’s recital sufficed to support plea | No challenge raised | No patent error; adequate factual basis |
| Legality of sentence | Sentence is legal in all respects | No challenge raised | Sentence legal; affirmed |
| Anders/Tyles/Benedict (withdrawal) procedure | Counsel conducted thorough review and moved to withdraw under Anders/Tyles/Benjamin | Defendant notified of rights; did not file pro se brief | Court independently reviewed record, found no nonfrivolous issues, granted withdrawal |
Key Cases Cited
- Anders v. California, 386 U.S. 738 (requires counsel seeking withdrawal to identify any nonfrivolous issues)
- Boykin v. Alabama, 395 U.S. 238 (pleas must be knowing, voluntary, and intelligent)
- State v. Tyles, 704 So. 2d 241 (La. 1997) (Louisiana application of Anders procedures)
- State v. Benjamin, 573 So. 2d 528 (La. App. 4th Cir.) (procedural guidance for appellate counsel withdrawal)
- State v. Price, 952 So. 2d 112 (scope of patent-error review under La. C.Cr.P. art. 920(2))