in the Interest of E.J.G., Z.M.E.G., and M.B.G., Children, 10-21-00217-CV

Joshua G. appealed a Navarro County judgment terminating his parental rights to three children (E.J.G., Z.M.E.G., M.B.G.).
Termination was based on a mediated settlement agreement and Joshua's voluntary affidavit of relinquishment.
Appointed appellate counsel filed an Anders brief asserting the appeal had no nonfrivolous issues and moved to withdraw; Joshua received the record and filed a pro se response listing potential issues.
The court independently reviewed the record and counsel’s Anders brief, as required in Anders proceedings for termination appeals.
The court concluded the appeal was frivolous and affirmed the trial court’s termination judgment.
The court denied counsel’s motion to withdraw because, under Texas Supreme Court precedent, filing an Anders brief alone does not necessarily establish the “good cause” required to permit withdrawal; counsel remains appointed for any supreme court proceedings.

Issue	Joshua's Argument	Department/Counsel's Argument	Held
Whether any non-frivolous appellate issues exist	Joshua listed multiple potential issues in a pro se response	Appellate counsel (Anders) contended no arguable issues exist after review	Court independently reviewed record and held appeal is frivolous (no meritorious issues)
Whether Anders procedures apply to parental-termination appeals	Implied acceptance of right to review and file pro se response	Counsel invoked Anders as applicable to termination appeals	Court applied Anders procedures (citing precedent) and reviewed record independently
Whether counsel may withdraw based solely on filing an Anders brief	Counsel moved to withdraw on basis that no arguable issues exist	State/Texas precedent: Anders motion to withdraw alone may be premature; need good cause beyond brief	Court denied motion to withdraw; counsel not relieved and remains appointed for further review
Scope of appeal when judgment is based on mediated settlement and affidavit of relinquishment	Joshua sought review of issues identified in his response	Counsel argued the mediated settlement and voluntary relinquishment limit appealable issues	Court noted the limited range of permissible issues and found none meritorious

Anders v. California, 386 U.S. 738 (1967) (procedure for appointed counsel to assert appeal frivolous and file brief)
In re E.L.Y., 69 S.W.3d 838 (Tex. App.—Waco 2002) (Anders procedures applicable to termination-of-parental-rights appeals)
In the Interest of P.M., 520 S.W.3d 24 (Tex. 2016) (An Anders motion to withdraw, without additional grounds, may be premature for purposes of withdrawal under Family Code)
In re Schulman, 252 S.W.3d 403 (Tex. Crim. App. 2008) (standards for appellate counsel’s duties when filing an Anders-type brief)
High v. State, 573 S.W.2d 807 (Tex. Crim. App. 1978) (procedural guidance for counsel duties in Anders context)
Stafford v. State, 813 S.W.2d 503 (Tex. Crim. App. 1991) (appellate court’s duty to independently examine record after Anders filing)
McCoy v. Court of Appeals, 486 U.S. 429 (1988) (definition of frivolous argument: cannot conceivably persuade the court)
In re G.P., 503 S.W.3d 531 (Tex. App.—Waco 2016) (affirming independent-review duty and standards in Anders context)