State v. Craig, 66 So. 3d 60

Defendant Al J. Craig was indicted in 2005 for second degree murder under LSA-R.S. 14:30.1; competency hearing followed and trial court found him competent.
Motions to suppress statement and to suppress identifications were denied by the trial court prior to trial.
In 2008 the State amended the indictment to manslaughter under LSA-R.S. 14:31; Craig pled guilty under North Carolina v. Alford and was sentenced to 23 years, with no multiple bill agreed by the State.
On appeal, counsel filed an Anders brief asserting no non-frivolous issues; defendant was given opportunity to file pro se supplemental brief but did not.
The record shows Craig was properly advised of Boykin rights and the consequences of the Alford plea; the plea colloquy and waiver form reflected the agreed sentence and protections.
The Anders review concluded no non-frivolous issues remained; the court affirmed conviction and sentence and granted counsel’s motion to withdraw.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Anders brief withdrawal was proper	Craig's counsel filed Anders brief alleging no non-frivolous issues.	No supplemental pro se brief filed; potential issues ambiguous but none preserved.	Counsel’s withdrawal granted; no non-frivolous issues found on independent review.
Validity of Alford plea and Boykin compliance	Plea knowingly and voluntarily entered with proper Boykin assurances.	Any deficiencies in plea colloquy could affect voluntariness or appeal.	Plea valid; proper Boykin rights and waiver ensured, no non-frivolous issues arising from plea.
Effect of plea on appeal rights and review of sentence	Sentence within statutory range and imposed under plea agreement.	Potential appellate review of sentence despite plea.	Sentence affirmed; Art. 881.2 precludes review of sentence imposed under a plea.

State v. Bradford, 676 So.2d 1108 (La.App. 5 Cir. 1996) (Anders briefing and withdrawal procedure supported)
State v. Jyles, 704 So.2d 241 (La. 1997) (Anders brief must show appellate review considered issues)
State v. Crosby, 338 So.2d 584 (La.1976) (preservation requirement for appeal review)
State v. Guzman, 769 So.2d 1158 (La.2000) (core Boykin requirements do not include sentencing advice)
State v. Broadway, 920 So.2d 960 (La.App. 2 Cir. 2006) (sentencing exposure not core Boykin; waiver suffices)
State v. Wingerter, 926 So.2d 662 (La.App. 5 Cir. 2006) (plea review and preservation limitations)
State v. McCoil, 924 So.2d 1120 (La.App. 5 Cir. 2006) (Alford plea requires strong evidence of actual guilt)
North Carolina v. Alford, 400 U.S. 25 (U.S. 1970) (permissible guilty plea while maintaining innocence)