Cooper v. State, 453 S.W.3d 147

Cooper pled guilty on Dec. 9, 2011 to attempted possession/intent to deliver a controlled substance, possession of drug paraphernalia, and driving with a suspended license; he was placed on probation.
The State later filed a petition to revoke probation for reporting failures, unabstained illegal-substance use, and unpaid fines/fees.
A revocation hearing occurred on Oct. 3, 2013, after which Cooper’s probation was revoked and he was sentenced to 18 months in a regional correctional facility with 24 months’ suspended imposition of sentence.
On Oct. 16, 2013, Cooper filed a pro se petition for appeal while still represented by trial counsel.
Substituted counsel filed a motion to withdraw with a no-merit brief under Anders; the trial court denied the withdrawal and ordered rebriefing.
The court directed that Cooper’s pro se points be served on the Attorney General pursuant to Rule 4-3(k)(3) for a responsive brief; it discussed the Anders framework and noted omissions in the brief.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether withdrawal under Anders was proper.	Cooper's counsel argued withdrawal under Anders due to lack of merit.	State argued the Anders framework was not properly satisfied due to omissions.	Denied withdrawal; rebriefing ordered.
Whether the court correctly applied Rule 4-3(k)(1) and (3) in assessing the no-merit brief.	Cooper's counsel complied with no-merit brief procedures; otherwise proper guidance should follow.	The brief failed to identify all adverse rulings and to invoke Anders/Rule 4-3(k) explicitly.	Court held that the brief did not clearly identify all adverse rulings and denied withdrawal; directed rebriefing and service to AG.

Anders v. California, 386 U.S. 738 (U.S. 1967) (no-merit brief framework; counsel must provide record references and argument for any potential merit)