Harris v. State, 2014 Ark. App. 5

Harris pleaded guilty to possession of a controlled substance in Sept. 2008 and was sentenced to five years of probation with conditions to pay fines, avoid alcohol and drugs, submit to testing, notify changes of address or employment, and procure suitable employment.
In Jan. 2011, the State filed a petition to revoke probation alleging multiple violations including nonpayment of fines, failure to report, address and employment updates, drug use, and failure to attend Drug Assessment.
A hearing found Harris had not paid fines and costs and Harris admitted recently smoking marijuana.
The trial court fined Harris with two days in jail and deferred sentencing until Aug. 2011; at a November 2011 hearing, sentencing was postponed again to allow compliance.
At a subsequent hearing Harris received a 30-day jail term and an April 2012 sentencing hearing, but he failed to appear at two later hearings, leading to a seven-year prison sentence.
Counsel filed a no-merit brief and motion to withdraw; Harris did not file points for reversal; the State did not file a brief.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether counsel's no-merit brief complied with Rule 4-3(k).	Harris	Harris	Court found deficiencies, denied withdrawal, and remanded for rebriefing

Walton v. State, 94 Ark. App. 229 (2006) (requires full review of lower court proceedings in no-merit appeals)
Anders v. California, 386 U.S. 738 (1967) (no-merit briefs must follow proper procedures)