Commonwealth of Pennsylvania, Appellee v. Israel Santiago, Appellant

Summary

The Pennsylvania Supreme Court affirmed the Superior Court's denial of appointed counsel's petition to withdraw under Anders, but on different grounds: counsel's brief was inadequate because it never reflected counsel's own independent, advocate's review of the record for arguable issues, not because it lacked developed legal argument or explained why issues were frivolous. The Court held that neither Anders nor McClendon requires legal argument, standards of review, or advocacy in a withdrawal brief, and it disapproved contrary lower-court decisions. Prospectively, the Court mandated that Anders briefs must state counsel's reasons for concluding the appeal is frivolous, effective for briefs where the briefing notice issues after the date of decision. No separate writings were filed.