State v. Kruebbe, 244 So. 3d 867

Jeffrey Kruebbe was charged in Jefferson Parish Second Parish Court with misdemeanor theft (La. R.S. 14:67) for taking cash from his former employer NAPA in early 2015.
NAPA's internal investigation and CCTV allegedly showed Kruebbe placing a key in the register, removing money, and later acknowledging responsibility in writing.
After various pro se motions and a sanity commission, Kruebbe entered an unconditional guilty plea on August 14, 2017, before an ad hoc judge and was represented by appointed counsel; he was sentenced to 30 days deferred parish prison, 11 months probation, and 30 hours community service.
Kruebbe sought supervisory writ review raising multiple claims: involuntary/coerced plea, due process violations, ineffective assistance of counsel, and assorted procedural complaints (including attempted federal removals).
The court reviewed the plea colloquy, Boykin waiver form, sentencing, and the record, and found the plea knowing and voluntary; it affirmed conviction and sentence but remanded to correct the minute entry which incorrectly referenced an Alford plea.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Kruebbe)	Held
Whether Kruebbe's guilty plea was constitutionally infirm / withdrawable	Plea was valid: colloquy and signed waiver show a knowing, voluntary plea	Plea was coerced, not knowing or voluntary; raised multiple due process defects	Court held plea was valid and not constitutionally infirm; refusal to vacate plea affirmed
Whether Kruebbe received ineffective assistance of counsel re: plea	Record shows plea was voluntary and below statutory maximum; no deficient performance shown	Counsel pressured/lied, coerced plea, and entered plea for him	Court found record sufficient to decide and held claim lacked merit — no prejudice shown
Whether minute entry misstated plea as an Alford plea	N/A (court identifies error)	Minute entry incorrectly records an Alford plea though transcript shows admission of guilt	Court granted limited relief: remanded to correct minute entry to delete reference to an Alford plea
Whether pre-plea procedural/venue/removal claims bar conviction or require relief	Procedural defects and federal removal attempts do not render plea infirm	Claimed due process violations, defective service, biased forum, sought removal to federal court	Because he entered unconditional guilty plea, non-jurisdictional pre-plea defects waived; claims not a basis to undo plea

Boykin v. Alabama, 395 U.S. 238 (defendant must knowingly waive trial, self-incrimination, confrontation rights)
Tollett v. Henderson, 411 U.S. 258 (guilty plea waives non-jurisdictional prior errors)
Strickland v. Washington, 466 U.S. 668 (two-prong ineffective assistance of counsel standard)
State v. Eiermann, 224 So.3d 1220 (La. App. 5 Cir.) (standards for withdrawing guilty plea)
State v. Starks, 812 So.2d 638 (La.) (unconditional guilty plea waives non-jurisdictional defects)
State v. Crosby, 338 So.2d 584 (La.) (plea review standards)
State v. Lynch, 441 So.2d 732 (La.) (transcript controls over conflicting minute entry)
North Carolina v. Alford, 400 U.S. 25 (Alford plea doctrine)