State v. Turner, 75 So. 3d 491

June 1, 2009 information charged Turner with felon in possession of a firearm and with possession with intent to distribute marijuana.
June 5, 2009 arraignment Turner pled not guilty; March 3, 2010 motions to suppress denied.
July 14, 2010 Turner pleaded guilty as charged to both counts, under a plea agreement sentencing: count one 10 years, first year without parole; count three 20 years, five years without parole; sentences concurrent.
State later filed a multiple offender bill; Turner stipulated, and the court vacated the original count-three sentence and imposed 20 years without parole as a second felony offender.
Turner appealed arguing denial of motions to suppress and suppression of statements, asserting protective sweep without articulable suspicion and that statements were fruit of the poisonous tree; State contends pleas were not Crosby-reserved, and Turner waived appellate rights by unqualified guilty pleas.
Court affirms convictions and sentences, but remands for limited corrections to commitments/minutes reflecting precise offenses, status, and concurrent run

Issue	Plaintiff's Argument	Defendant's Argument	Held
Preservation of pre-plea suppression review under Crosby	State argues Turner did not reserve Crosby rights; appeal allowed only if Crosby reservation exists	Turner contends Crosby reservation was implicit in plea proceedings and warrant review	Waived review; no Crosby reservation found; appeal limited/denied on suppression issues
Errors patent and commitment corrections on sentencing	State acknowledges potential minor errors but their remedy is limited to corrections	N/A (Turner not contesting patent errors beyond standard review)	Convictions affirmed; remanded to correct commitments/minutes for precise statutory language and concurrent sentencing clarification
Whether the sentence under 14:95.1 was illegally lenient or improperly imposed	State notes self-activating nature of sentencing; no corrective action required	N/A (no direct challenge)	Illegal-leniency issue not remedied; no action required; however, other commitments remanded for clarification

State v. Crosby, 338 So.2d 584 (La. 1976) (reservations to appeal pre-trial rulings under Crosby must be clearly made at plea)
State v. Reed, 61 So.3d 74 (La.App. 5 Cir. 2011) (review of Crosby rights when reserved via pleading)
State v. Richardson, 33 So.3d 903 (La. App. 5 Cir. 2010) (failure to expressly reserve Crosby rights precludes appeal)
State v. Michael, 454 So.2d 847 (La.App. 5 Cir. 1984) (motion for appeal granting does not preserve Crosby rights absent explicit reservation)
State v. Welch, 28 So.3d 293 (La.App. 5 Cir. 2009) (patent errors may be corrected; appeals limited when pleas favorable to defendant)