Com. v. Brown, D., Com. v. Brown, D. No. 1175 WDA 2016

Brown punched a male victim in a July 9, 2015 fight causing serious injuries.
Brown had sexual intercourse with a 15-year-old female victim on November 14, 2015.
Brown pled guilty to simple assault and corruption of minors on May 4, 2016.
The trial court imposed consecutive 12–24 month sentences for each offense on July 8, 2016.
Counsel filed an Anders brief and petition to withdraw on December 12, 2016.
The Superior Court affirmed, ruling the appeal was wholly frivolous after independent review.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Brown's sentence is manifestly excessive under the Sentencing Code.	Brown	Commonwealth	Wholly frivolous; affirmed

Commonwealth v. Lilley, 978 A.2d 995 (Pa. Super. 2009) (counsel compliance and need for independent review when withdrawing under Anders)
Santiago, 978 A.2d 349 (Pa. 2009) (Anders requirements and client notification about rights)
Commonwealth v. Hill, 66 A.3d 359 (Pa. Super. 2013) (substantial question standard for discretionary sentencing")
Commonwealth v. Moury, 992 A.2d 162 (Pa. Super. 2010) (court weighed relevant sentencing factors and pre-sentence info)
Cartrette, 83 A.3d 1030 (Pa. Super. 2013) (waiver rules for discretionary sentencing challenges; but review may proceed when Anders filed)
Commonwealth v. Johnson, 125 A.3d 822 (Pa. Super. 2015) (standard of review for sentencing challenges; abuse-of-discretion standard)
Commonwealth v. Derry, 150 A.3d 987 (Pa. Super. 2016) (failure to consider sentencing criteria can raise substantial question)
Commonwealth v. Best, 120 A.3d 329 (Pa. Super. 2015) (discretionary sentencing issues treated as appeal petitions; need for substantial question)