State v. Howard, 2017 Ohio 1387

Jamar C. Howard was indicted on multiple counts: two counts of complicity to commit murder (proximate result; deadly weapon and serious physical harm) and two counts of complicity to commit aggravated robbery (deadly weapon and serious physical harm), each with three-year firearm specifications.
Howard pled not guilty, waived a jury, and was tried to the court on January 11–12, 2016.
The trial court found Howard guilty of all counts and at sentencing merged the murder counts (proceeding on one) and the robbery counts (proceeding on one).
Sentences: Count I (complicity to commit murder) — 15 years to life + 3-year firearm specification (consecutive and prior); Count IV (complicity to commit aggravated robbery) — 7 years + 3-year firearm specification (consecutive to 7 years). Count IV was ordered concurrent to Count I, producing an aggregate sentence of 18 years to life; restitution $824 (stayed).
Appellate counsel, concluding any appeal would be frivolous, filed a motion to withdraw under Anders v. California and provided the required Anders brief; Howard did not file a pro se brief.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether appellate counsel complied with Anders procedures to withdraw	State did not contest compliance; urged the court to review record	Counsel asserted no meritorious issues; Howard filed nothing pro se	Court found counsel complied with Anders and proceeded to review the record
Whether the appeal presented any arguable (non-frivolous) issues challenging conviction or sentence	State maintained convictions and sentencing were proper	Counsel maintained appeal was wholly frivolous; no assignments of error presented	Court conducted independent review, found no arguably meritorious issues, and affirmed the trial court judgment

Anders v. California, 386 U.S. 738 (U.S. 1967) (sets procedure for defense counsel to withdraw when appeal is frivolous; requires counsel to file brief identifying potential issues and court to review the record independently)