State v. Baker, 179 So. 3d 895

Defendant Brian S. Baker was charged with possession with intent to distribute cocaine and marijuana based on events of March 13, 2014; he pled guilty under State v. Crosby after pretrial rulings.
A confidential informant arranged a controlled buy at the Siesta Motel, which Agent Washington observed; defendant was arrested about 72 hours later on outstanding warrants.
After arrest, Agent Buttoné went to the motel room where defendant had been staying; Taniesha Nash signed a consent-to-search form and officers seized narcotics and distribution-related items.
Defendant moved to suppress evidence from the motel room and to compel disclosure of the CI’s identity; the trial court denied suppression and refused to reveal the CI but limited testimony to what the officer personally observed.
Defendant pleaded guilty after those rulings; the court later adjudicated him a second-felony offender and resentenced him. The appellate court affirmed and remanded only to correct an inconsistent Uniform Commitment Order.

Issue	State's Argument	Baker's Argument	Held
Validity of warrantless search of motel room (consent)	Nash freely and voluntarily consented; she appeared to have authority as a co-occupant	Search was illegal; Nash’s consent coerced (was allegedly naked, screamed) and room was defendant’s	Denial of suppression affirmed: consent was reasonable and voluntary; officers reasonably believed Nash had authority to consent
Disclosure of confidential informant identity	CI identity privileged; no exceptional circumstances shown; officers personally observed the buy and charges based on later seizure	Defendant needed CI identity to confront and prepare defense regarding the controlled buy	Denial affirmed: CI privilege upheld; no showing of necessity or exceptional circumstances; officer testimony limited to firsthand observations
Pro se claim that arrest was illegal / evidence insufficient	State notes arrest was on outstanding warrants; Crosby plea limits review to preserved pretrial rulings	Arrest was an illegal stop/arrest and evidence insufficient to convict	Rejected as not preserved for appellate review (court did not rule on arrest validity); sufficiency claim barred by guilty plea
Patent error in commitment documents	N/A	N/A	Remanded to correct Uniform Commitment Order to conform to transcript/minute entry regarding which portions of sentence are without benefits

Matlock, 415 U.S. 164 (third‑party common authority can validate consent to search)
Illinois v. Rodriguez, 497 U.S. 177 (officers’ reasonable, albeit erroneous, belief in third‑party authority can justify warrantless entry)
State v. Crosby, 338 So.2d 584 (La. 1976) (scope of appellate review when defendant pleads guilty)
State v. Flagg, 760 So.2d 522 (La. App. 5 Cir.) (standard of review for suppression denials)
State v. Clark, 909 So.2d 1007 (La. App. 5 Cir.) (informant identity privilege and exception analysis)
State v. Addison, 920 So.2d 884 (La. App. 5 Cir.) (fact patterns supporting reasonable belief of third‑party authority to consent)
State v. Lynch, 441 So.2d 732 (La. 1988) (transcript controls when minutes conflict)