Goodman v. State
2014 Ark. App. 45
Ark. Ct. App.2014Background
- Appellant Goodman’s probation for endangering the welfare of a minor was revoked after violation findings; she received a two-year term in a Community Correction Center.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)
