Commonwealth v. Washington, 63 A.3d 797

Appellant was convicted of possession with intent to deliver, possession of a controlled substance, firearms not to be carried without a license, and felon not to possess a firearm, and appealed while counsel sought Anders/Santiago relief.
Police stopped a green Volvo after a confidential informant report; three occupants were searched and Appellant was found with a loaded Luger P85, cocaine, and money.
Pretrial suppression motions were heard February 22, 2011, and denied; motions included suppression and disclosure of the confidential informant.
On March 23, 2011, a stipulated bench trial yielded the above convictions and a 5–10 year aggregate sentence; Appellant did not file post-sentence motions but timely appealed.
Appellant’s counsel sought withdrawal under Anders/Santiago; the Superior Court conducted independent review and granted counsel’s withdrawal, affirming the judgment.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court abused discretion in denying disclosure of the confidential informant	Appellant argues the informant’s identity should be disclosed to challenge reliability.	Commonwealth asserts privilege and that disclosure is not warranted given the circumstances.	No abuse; denial proper; informant disclosure not required under the balance of interests.
Whether the stop of the Volvo was supported by reasonable suspicion	Appellant contends there was no reasonable suspicion for the stop and search.	Commonwealth contends information from a reliable informant and dispatch details justified the stop.	Reasonable suspicion existed; stop proper under totality of circumstances.
Whether the handwritten letter from the confidential informant could be used to cross-examine Detective Fedak	Appellant sought to use the letter to challenge informant reliability and the stop.	Letter is hearsay and not admissible to prove truth of content or to impeach reliability.	Letter classified as hearsay without a valid exception; inadmissible for cross-examination.
Whether appellate counsel's Anders/Santiago withdrawal was properly granted	Appellant's counsel argued issues were non-meritorious and required withdrawal.	Counsel complied with Anders/Santiago procedures and independently reviewed the record.	Wholly frivolous; withdrawal granted; judgment affirmed.

Commonwealth v. Withrow, 932 A.2d 138 (Pa.Super.2007) (abuse of discretion standard for informant-disclosure rulings)
Commonwealth v. Belenky, 777 A.2d 483 (Pa.Super.2001) (balancing test for informant disclosure when not eyewitness)
Commonwealth v. Cruz, 21 A.3d 1247 (Pa.Super.2011) (reasonable suspicion in vehicle stops from tips/dispatches)
Commonwealth v. Barber, 889 A.2d 587 (Pa.Super.2005) (reliability and veracity of informants in totality-of-circumstances analysis)
Commonwealth v. Ali, 608 Pa. 71 (Pa.2010) (hearsay and non-hearsay relevance; multiple exceptions)
Commonwealth v. Levanduski, 907 A.2d 3 (Pa.Super.2006) (complete story doctrine and other hearsay considerations)
Commonwealth v. Santiago, 602 Pa. 159 (Pa.2009) (standards for Anders/Santiago withdrawal on appeal)
Anders v. California, 386 U.S. 738 (1967) (principles for counsel-initiated withdrawal on appeal)