T.S. v. State, 2017 Ark. App. 398

Juvenile T.S. was adjudicated delinquent by the Ouachita County Circuit Court for first-degree criminal mischief after a bench trial.
Counsel for T.S. filed a no-merit (Anders-style) brief and a motion to withdraw under Ark. Sup. Ct. R. 4-3(k), asserting no meritorious appellate issues.
The circuit court sustained three evidentiary objections made by the State during trial; those rulings were listed in the brief but abstracted incompletely.
Counsel’s brief failed to address the circuit court’s adverse delinquency finding and did not explain why that ruling lacked merit for appeal.
The Court of Appeals found the abstract incomplete and the argument deficient, ordered rebriefing, and denied counsel’s motion to withdraw.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether counsel’s no-merit brief adequately abstracted and explained adverse evidentiary rulings	State: adverse evidentiary rulings were made and are relevant for appeal	T.S. (through counsel): the listed adverse rulings are not meritorious grounds for reversal	Court: Abstracting was incomplete and lacked context; rebriefing ordered
Whether counsel’s brief must address the adjudication (delinquency finding)	State: delinquency finding is an adverse ruling to be addressed	T.S.: brief did not address the delinquency finding (no argument provided)	Court: Failure to address the delinquency finding violates Rule 4-3(k)(1); rebriefing ordered
Whether counsel may be permitted to withdraw under Anders and Rule 4-3(k)	Counsel: moved to withdraw, asserting no nonfrivolous issues	State: opposed implicit in court’s demand for compliance with briefing rules	Court: Motion to withdraw denied; counsel ordered to cure deficiencies and file substituted brief

Anders v. California, 386 U.S. 738 (U.S. 1967) (establishes procedure for counsel to seek withdrawal when appellate issues are frivolous)
Sartin v. State, 362 S.W.3d 877 (Ark. 2010) (no-merit brief must address all adverse rulings; failure requires rebriefing)