State v. Julien, 225 So. 3d 1197

Jeremy C. Julien was indicted on felony counts including second-degree murder (amended to manslaughter), distribution of heroin, possession with intent to distribute heroin, possession of a firearm by a convicted felon, and possession of hydrocodone.
On September 17, 2014, Julien pleaded guilty to manslaughter (count one) and to counts two through five; sentences were imposed per plea agreement and ordered to run concurrently.
The State filed a La. R.S. 15:529.1 multiple offender bill as to count two; Julien stipulated and was adjudicated a second felony offender and re-sentenced accordingly.
Julien filed a pro se motion to reconsider sentence (denied) and later obtained an out-of-time appeal; appellate counsel submitted an Anders brief seeking leave to withdraw.
Julien filed a pro se supplemental brief alleging involuntary guilty pleas based on ineffective assistance of counsel (counsel allegedly told him he would serve only 18 years of a 40-year enhanced term).
The appellate court independently reviewed the record, found the pleas, multiple offender stipulation, and sentences valid, affirmed as amended (removing an improper parole restriction on one count), remanded to correct ministerial commitment/minute errors, and granted counsel’s motion to withdraw.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Voluntariness and validity of guilty pleas	State: Pleas were knowingly, intelligently, and voluntarily entered after proper Boykin colloquy and written waivers	Julien: Pleas were involuntary, induced by counsel's erroneous advice about time to be served (ineffective assistance)	Court: Pleas were valid on the record; ineffective-assistance claim is more appropriate for post-conviction relief
Validity of multiple offender stipulation	State: Defendant knowingly and intelligently stipulated to the multiple bill	Julien: (challenges tied to counsel performance)	Court: Stipulation was valid; rights were advised and waiver was voluntary
Reviewability of sentences imposed under plea agreement	State: Sentences conformed to plea agreement and statutory ranges	Julien: Seeks relief based on alleged reliance on counsel's promises regarding good time	Court: Sentences are not reviewable where imposed in conformity with plea agreement; within statutory ranges
Errors patent (parole restriction and clerical entries)	State/Court: Review the record for patent errors	Julien: N/A (did not raise these)	Court: Amended sentence to remove unauthorized parole restriction on count three; directed correction of minute entries and commitment orders to reconcile transcript and correct offense dates

State v. Bradford, 676 So.2d 1108 (La. App. 5th Cir. 1996) (procedure for Anders brief and counsel withdrawal)
Boykin v. Alabama, 395 U.S. 238 (U.S. 1969) (constitutional requirement that guilty plea be voluntary and knowing)
State v. Lynch, 441 So.2d 732 (La. 1983) (transcript controls over minutes when discrepant)
State v. Oliveaux, 312 So.2d 337 (La. 1975) (requirement to review records for errors patent)
State v. Crosby, 338 So.2d 584 (La. 1976) (preservation rules for pre-plea rulings)