State v. Kent, 178 So. 3d 219

Kent pled guilty to possession with intent to distribute marijuana and possession of a firearm by a convicted felon; sentences were imposed and later enhanced under a habitual offender statute.
The trial court sentenced Kent to 18 years on count one and 18 years on count two, with those sentences to run concurrently, and then increased count one under the habitual offender statute to 18 years, concurrent with count two.
Counsel for Kent filed an Anders brief seeking withdrawal, asserting no non-frivolous issues remained on appeal.
Kent filed a pro se supplemental brief raising multiple challenges, including the adequacy of Boykin-type colloquy, minimum-sentence advisements, suppression hearing conduct, and other plea-related concerns.
The appellate court conducted an independent review, concluded there were no non-frivolous appellate issues, and granted counsel’s motion to withdraw; it affirmed the convictions and sentences and remanded for correction of the commitment to reflect transcript language.
The court addressed several pro se claims as meritless or unpreserved, and noted errors patent issues regarding fines and commitment wording, which it chose to correct on remand.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Anders withdrawal proper	Kent	Bradford/Jyles standards satisfied	Yes; no non-frivolous issues found on independent review.
Confrontation/right-to-minimum-sentence advisement	Kent	Advisement lacking or inadequate	Harmless or not reversible; advisement through waiver and colloquy upheld.
Habitual offender validity and prior convictions	Kent	Clerical errors and improper conviction use	Waived due to stipulation; no reversible error; no need for further proof.
Plea negotiations and judge’s participation	Kent	Judge improperly participated in plea negotiations	No reversible error; record shows no improper participation.
Errors patent and commitment inconsistency	Kent	Commitment contradicts transcript regarding concurrency	Remand for correction of commitment to match transcript; no impact on affirmed convictions.

State v. Bradford, 676 So.2d 1108 (La.App. 5 Cir. 1996) (Anders framework in Louisiana review of appellate counsel withdrawal)
State v. Jyles, 704 So.2d 241 (La. 1997) (Anders requirements; no need to catalog all frivolous pretrial motions)
Boykin v. Alabama, 395 U.S. 238 (1969) (Informs that no magic words are required in waiver of rights)
State v. Mendenhall, 944 So.2d 560 (La. 2006) (Tailored admonitions suffice to convey waiver of confrontation right)
State v. Crosby, 338 So.2d 584 (La. 1976) (Preservation requirements for appellate review of suppressions and pleas)
State v. Schaefer, 704 So.2d 300 (La. App. 5 Cir. 1997) (Habitual offender proof burden and waiver effects of stipulation)
State v. Spellman, 140 So.3d 751 (La. App. 5 Cir. 2014) (Habitual offender proof and non-jurisdictional defects waived by plea)