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Goodman v. State
2014 Ark. App. 45
Ark. Ct. App.
2014
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Background

  • Appellant Goodman’s probation for endangering the welfare of a minor was revoked after violation findings; she received a two-year term in a Community Correction Center.
  • Counsel moved to withdraw, asserting the appeal is wholly without merit; Goodman did not file pro se points for reversal.
  • The court advised counsel that a no-merit brief must abstract and discuss all adverse rulings and argue why they are not grounds for reversal.
  • Court found counsel failed to meet Anders requirements and failed to address Goodman’s sentencing request for house arrest or similar relief.
  • The court denied the withdrawal, ordered rebriefing, and gave Goodman 15 days to file a substituted abstract, brief, and addendum.
  • The decision cites Anders v. California and Arkansas Supreme Court rules guiding no-merit briefs and withdrawal procedures.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Whether counsel’s withdrawal is proper under no-merit brief standards Goodman Goodman’s counsel failed to comply with Anders and Rule 4-3(k) standards Withdrawal denied; rebriefing ordered.

Key Cases Cited

  • Anders v. California, 386 U.S. 738 (1967) (no-merit brief requirements; within-procedural review)
  • Eads v. State, 74 Ark. App. 363, 47 S.W.3d 918 (2001) (counsel withdrawal standards in Arkansas)
  • Campbell v. State, 74 Ark. App. 277, 47 S.W.3d 915 (2001) (discusses Anders-related obligations)
  • Sartin v. State, 2010 Ark. 16, 362 S.W.3d 877 (2010) (analysis of no-merit briefing requirements)
Read the full case

Case Details

Case Name: Goodman v. State
Court Name: Court of Appeals of Arkansas
Date Published: Jan 15, 2014
Citation: 2014 Ark. App. 45
Docket Number: CR-13-649
Court Abbreviation: Ark. Ct. App.