Com. v. Wilson, F., 1878 MDA 2016

Police used a confidential informant (CI) to purchase crack cocaine from a man identified as “Vonday” on May 28 and June 2, 2015; both buys involved a blue Buick and small Ziploc packaging.
On June 4, 2015, a buy-bust was conducted; officers stopped the same blue Buick, arrested appellant Fontain S. Wilson, recovered three bags of crack that matched earlier buys, and found a phone with the target number.
Wilson gave a statement after receiving Miranda warnings, admitted selling drugs, consented to a home search, and led officers to cocaine, Ziploc baggies, paraphernalia, and cash in his residence.
Wilson was convicted after a bench trial of criminal use of a communication facility, two counts of delivery of a controlled substance, possession with intent to deliver, and possession of drug paraphernalia.
The court imposed an aggregate sentence of 2–4 years’ incarceration plus 1 year of probation (with some counts concurrent and others consecutive); Wilson appealed the discretionary aspects of sentencing arguing the consecutive terms were an abuse of discretion and excessive.
Appointed appellate counsel filed an Anders brief and moved to withdraw, concluding the appeal was frivolous; the Superior Court reviewed counsel’s compliance with Anders procedures and conducted independent review.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether trial court abused discretion by running two sentences consecutively, producing 2–4 years aggregate	Wilson: consecutive sentences were excessive and court failed to consider rehabilitative needs and public protection; requested concurrent sentences	Commonwealth: sentence was within guideline range, properly considered, and sentencing discretion was not abused	Court: No abuse of discretion; sentence within guidelines and justified; affirmed

Anders v. California, 386 U.S. 738 (U.S. 1967) (standards for counsel seeking to withdraw on appeal when appeal deemed frivolous)
Commonwealth v. Santiago, 978 A.2d 349 (Pa. 2009) (requirements for Anders brief content in Pennsylvania)
Commonwealth v. Moury, 992 A.2d 162 (Pa. Super. 2010) (four-part test for discretionary sentencing claims)
Commonwealth v. Swope, 123 A.3d 333 (Pa. Super. 2015) (when a substantial question exists re: consecutive sentences and rehabilitative considerations)
Commonwealth v. Flowers, 113 A.3d 1246 (Pa. Super. 2015) (procedural protections and obligations when counsel seeks to withdraw under Anders)