State v. Shelton, 207 So. 3d 549

Shelton pleaded guilty to attempted first degree robbery with a 15-year sentencing cap after a mistrial on armed robbery charges.
The plea agreement provided a cap and included a presentence investigation report; conspiracy and illegal firearm charges were nol prossed.
At sentencing, the court considered the PSI and about 20 letters, including one from Shelton and one from the store owner, and imposed 14 years at hard labor, one year under the cap, with treatment recommended.
Defense counsel withdrew after sentencing; Shelton pro se appealed, and appellate counsel filed an Anders brief seeking to withdraw.
The appellate court held the sentence was within the plea cap and precluded review, found an error patent regarding parole status that is self-correcting, and affirmed the conviction and sentence with directions to amend minutes.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the sentence is reviewable given the plea cap	Shelton's sentence was within an agreed cap, precluding appeal.	Potential review of sentencing despite plea cap.	Sentence not reviewable due to plea cap.
Whether appellate withdrawal under Anders was proper	Counsel conducted thorough review and found no nonfrivolous issues.	No meaningful issues to raise upon appeal.	Motion to withdraw granted; conviction and sentence affirmed.
Whether any error patent affected the sentence and requires correction	No major sentencing errors; the record supports the sentence.	Potential sentencing errors could be remediable on appeal.	Error patent found: absence of parole/probation/suspension notation; self-correcting under statute; minutes to be amended.
Whether the 14-year sentence was excessive under the circumstances	Store clerk faced grave danger from armed robbers; sentence within cap is appropriate.	Arguably disproportionate without parole consideration.	Not excessive under the facts and plea agreement; affirmed.

Anders v. California, 386 U.S. 738 (U.S. Supreme Court 1967) (established procedure for Anders briefs in frivolous-appeal cases)
State v. Young, 680 So.2d 1171 (La. 1996) (plea-based sentencing review constraints)
State v. Jones, 163 So.3d 875 (La.App. 2 Cir. 2015) (analysis of sentencing cap under plea agreement)
State v. Holton, 198 So.3d 201 (La.App. 2 Cir. 2016) (conforms to plea-cap sentencing framework)
State v. Williams, 800 So.2d 790 (La. 2001) (self-correcting correction of illegally lenient sentence)
State v. Smith, 184 So.3d 241 (La.App. 2 Cir. 2016) (ministerial correction to sentencing minutes)
State v. Jackson, 130 So.3d 993 (La.App. 2 Cir. 2014) (maximum sentence under statutory framework for attempted robbery)
State v. Banks, 136 So.3d 937 (La.App. 2 Cir. 2014) (appeal-time and waiver considerations in plea cases)
State v. Fizer, 986 So.2d 243 (La.App. 2 Cir. 2008) (appeal viability after guilty plea and waivers)
Jyles v. State, 704 So.2d 241 (La. 1997) (Anders-based withdrawal standards guidance)
State v. Mouton, 653 So.2d 1176 (La. 1995) (Anders/Jyles line of nonfrivolous-issues framework)
State v. Benjamin, 573 So.2d 528 (La.App. 4th Cir. 1990) (Anders-related appellate representation standards)