State v. Sayles, 206 So. 3d 1243

On Dec. 4, 2014, Wal‑Mart employees stopped Clarence Sayles leaving with a 60" TV because the serial number on the receipt (ending in 144) did not match the TV (ending in 143). Sayles called 9‑1‑1 claiming unlawful detention.
Jefferson Parish deputies Farris and West responded; Sayles identified himself only as "Clarence" and refused to provide a last name or other identification despite repeated requests.
Officers compared the receipt and TV, concluded theft had occurred, and arrested Sayles. While being escorted inside, Sayles allegedly fell, refused to walk or cooperate, and had to be carried to loss prevention.
A bill of information charged Sayles with two counts of resisting an officer (La. R.S. 14:108) and a separate felony theft charge; this opinion concerns the two misdemeanors tried to the bench.
At the Oct. 28, 2015 bench trial the judge found Sayles guilty on both misdemeanor counts; the court denied a new‑trial motion and imposed concurrent six‑month suspended sentences with six months inactive probation.
Appellate counsel filed an Anders brief, asserting no non‑frivolous issues for appeal; this Court independently reviewed the record and affirmed convictions and sentences and granted counsel leave to withdraw.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence to convict of resisting an officer	State: testimony showed Sayles refused to identify himself and refused to cooperate, supporting conviction under La. R.S. 14:108	Sayles: (via Anders brief — no meritorious claim identified) argued generally that law/evidence did not support convictions	Court: Under Jackson v. Virginia standard, evidence was sufficient; convictions affirmed
Proper appellate procedure for misdemeanor review	State/Court: supervisory writ review is the correct procedural route for non‑jury misdemeanor convictions	Sayles: filed an appeal initially (procedural error)	Court converted designation to permit supervisory review rather than dismissing appeal
Counsel withdrawal under Anders	Appointed counsel: no non‑frivolous issues; requested withdrawal after informing defendant of right to file pro se brief	Sayles: did not file a pro se brief (letter returned unclaimed)	Court performed independent review, found no meritorious issues, and granted counsel’s motion to withdraw
Sentencing legality	State: sentences fell within statutory range and ran concurrently with felony sentence	Sayles: argued sentences unsupported by record/new trial motion raised insufficiency	Court: sentences were within statutory limits; affirmed and found no errors patent

Anders v. California, 386 U.S. 738 (U.S. 1967) (procedures for counsel withdrawal when no meritorious appellate issues exist)
Jackson v. Virginia, 443 U.S. 307 (U.S. 1979) (standard for reviewing sufficiency of the evidence)
State v. Jyles, 704 So.2d 241 (La. 1997) (Anders‑style review guidance in Louisiana)
State v. Lyons, 128 So.3d 407 (La. App. 5th Cir. 2013) (Anders review applied to misdemeanor consolidated with felony appeal)
State v. Brooks, 595 So.2d 777 (La. App. 5th Cir. 1992) (errors‑patent review in appellate supervisory proceedings)
State v. Carruth, 643 So.2d 1319 (La. App. 5th Cir. 1994) (treating misdemeanor appeal as supervisory review and conducting errors‑patent review)