Com. v. Mathis, C., 1884 WDA 2015

Appellant Chaz Montie Mathis was arrested April 20, 2015 after police found 28 grams of crack cocaine and a 9mm handgun in constructive possession at a residence. He pled guilty to PWID and unlawful possession of a firearm.
On October 29, 2015 the court imposed an aggregate sentence of 90 to 180 months’ imprisonment (with credit for time served); a separate consecutive 12–24 month sentence at a different docket is noted but not appealed here.
Appellant filed a post-sentence motion complaining the court abused its discretion by running sentences consecutively; the court later ordered concurrency with the other docket.
Counsel filed an Anders brief seeking leave to withdraw, raising a discretionary-sentencing challenge that the sentence was manifestly excessive and that the court failed to consider mitigating factors (acceptance of responsibility; caregiver status).
The trial court had a PSI and explicitly stated on the record it considered the Sentencing Code, the PSI, guidelines, appellant’s background, prior record (score of five), rehabilitative needs, and the nature and seriousness of the offenses when imposing a standard-range sentence.
The Superior Court concluded counsel complied with Anders/Santiago/Millisock formalities, conducted an independent review, found the discretionary-sentencing claim frivolous, granted counsel’s withdrawal, and affirmed the judgment of sentence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether appellant’s sentence is manifestly excessive and inconsistent with the Sentencing Code	Mathis: sentence (90–180 months) is excessive; court failed to adequately weigh mitigating factors (plea/acceptance, caregiver responsibilities) and § 9721(b) factors	Court/Commonwealth: sentencing court considered PSI, § 9721(b) factors, guidelines, prior record, and gave benefit of standard-range sentence despite aggravating history	Affirmed: appellate court found sentencing court considered relevant factors, rejected claim as frivolous except that rehabilitative-need argument raised a substantial question which was meritless on review
Whether counsel complied with Anders withdrawal requirements	N/A (procedural)	Counsel: Anders brief summarized record, cited arguable issue, concluded frivolous, and provided Millisock notice to client	Granted: Superior Court found procedural requirements satisfied and permitted counsel to withdraw

Anders v. California, 386 U.S. 738 (1967) (framework for counsel seeking to withdraw on appeal)
Commonwealth v. Santiago, 978 A.2d 349 (Pa. 2009) (Anders brief substantive requirements in Pennsylvania)
Commonwealth v. Millisock, 873 A.2d 748 (Pa. Super. 2005) (requirement to provide client a copy of Anders brief and notice)
Commonwealth v. Goodwin, 928 A.2d 287 (Pa. Super. 2007) (appellate court must conduct independent review after Anders compliance)
Commonwealth v. Carrillo-Diaz, 64 A.3d 722 (Pa. Super. 2013) (four-part test to invoke review of discretionary aspects of sentence)
Commonwealth v. Caldwell, 117 A.3d 763 (Pa. Super. 2015) (challenge to consecutive sentences plus failure to consider rehabilitative needs can present substantial question)
Commonwealth v. Zirkle, 107 A.3d 127 (Pa. Super. 2014) (standards for reviewing discretionary sentencing claims)
Commonwealth v. Antidormi, 84 A.3d 736 (Pa. Super. 2014) (presumption that sentencing court considered relevant information when PSI is available)