in the Interest of C.S. and T.L. Children v. Department of Family and Protective Services, 01-16-00152-CV

Trial court terminated father's parental rights to his sons, C.S. and T.L.; father sought to appeal.
Trial court appointed appellate counsel; counsel concluded the appeal was frivolous and filed an Anders brief seeking leave to withdraw.
Counsel certified delivery of the Anders brief to the father and notified him of his right to review the record and file a pro se response; the father did not respond.
The Court of Appeals conducted an independent review of the entire record per Anders procedures to determine whether arguable grounds for appeal existed.
The court concluded no reversible error existed, affirmed the termination judgment, and denied counsel's motion to withdraw (while explaining counsel’s obligations continue through further appellate remedies).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Adequacy of Anders brief	Father (through counsel) implicitly argues a meaningful appeal should proceed	Appellate counsel argues he conducted a complete review and found no arguable grounds	Brief met Anders/Schulman minimum; court accepted it as adequate
Independent-review requirement	Father seeks reversal; asserts issues (none filed pro se)	Appellate court must independently review record for arguable grounds	Court performed independent review and found no arguable grounds
Whether counsel may withdraw	Father wants counsel to continue appellate representation	Counsel seeks leave to withdraw because appeal is frivolous; ethical duty not to prosecute frivolous appeals	Court denied counsel’s motion to withdraw but affirmed judgment; counsel must continue obligations through further appeals if pursued
Disposition of termination judgment on appeal	Father seeks reversal of termination	Appellate court reviews for reversible error after Anders brief	Court found no reversible error and affirmed the trial court judgment

Anders v. California, 386 U.S. 738 (1967) (establishes procedures when appointed counsel deems appeal frivolous)
In re Schulman, 252 S.W.3d 403 (Tex. Crim. App. 2008) (articulates Texas standards for Anders briefs and counsel’s duties)
Bledsoe v. State, 178 S.W.3d 824 (Tex. Crim. App. 2005) (procedure when appellate court finds arguable grounds for appeal)
Garner v. State, 300 S.W.3d 763 (Tex. Crim. App. 2009) (court may explain why appeal lacks arguable merit but is not required to)
In re K.D., 127 S.W.3d 66 (Tex. App.—Houston [1st Dist.] 2003) (Anders procedures are appropriate in parental-rights termination cases)