260
Syllabus
that procedure. The court, however, remanded the case for the District Court to consider other trial errors raised by Robbins.
Held:
1. The Anders procedure is only one method of satisfying the Constitution's requirements for indigent criminal appeals; the States are free to adopt different procedures, so long as those procedures adequately safeguard a defendant's right to appellate counsel. Pp. 269-276.
(a) In finding that the California procedure at issue in Anders— which permitted appellate counsel to withdraw upon filing a conclusory letter stating that the appeal had "no merit" and permitted the appellate court to affirm the conviction upon reaching the same conclusion following a review of the record—did not comport with fair procedure and lacked the equality that the Fourteenth Amendment requires, this Court placed the case within a line of precedent beginning with Griffin v. Illinois, 351 U. S. 12, and continuing with Douglas v. California, 372 U. S. 353, that imposed constitutional constraints on those States choosing to create appellate review. Comparing the California procedure to other procedures that this Court had found invalid and to statutory requirements in the federal courts governing appeals by indigents with appointed counsel, the Court concluded that the finding that the appeal had "no merit" was inadequate because it did not mean that the appeal was so lacking in prospects as to be frivolous. The Court, in a final, separate section, set out what would be an acceptable procedure for treating frivolous appeals. Pp. 269-272.
(b) The Ninth Circuit erred in finding that Anders' final section, though unnecessary to the holding in that case, was obligatory upon the States. This Court has never so held; its precedents suggest otherwise; and the Ninth Circuit's view runs contrary to this Court's established practice. In McCoy v. Court of Appeals of Wis., Dist. 1, 486 U. S. 429, this Court rejected a challenge to Wisconsin's variation on the Anders procedure, even though that variation, in at least one respect, provided less effective advocacy for an indigent. In Pennsylvania v. Finley, 481 U. S. 551, the Court explained that the Anders procedure is not an independent constitutional command, but rather a prophylactic framework; it did not say that this was the only framework that could adequately vindicate the right to appellate counsel announced in Douglas. Similarly, in Penson v. Ohio, 488 U. S. 75, the Court described Anders as simply erecting safeguards. Finally, any view of the procedure described in Anders' last section that converted it from a suggestion into a straitjacket would contravene this Court's established practice of allowing the States wide discretion, subject to the minimum require-
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