Cite as: 528 U. S. 259 (2000)
Opinion of the Court
counsel stating only his "bare conclusion" that the appeal had no merit was insufficient. 386 U. S., at 742. It is unclear from our opinion in Anders how much our objection on this point was severable from our objection to the lack of a finding of frivolity, because we immediately followed our description of counsel's "no merit" letter with a discussion of Ellis, Eskridge, and Lane, and the lack of such a finding. See 386 U. S., at 742-743. In any event, the Wende brief provides more than a one-paragraph "bare conclusion." Counsel's summary of the case's procedural and factual history, with citations of the record, both ensures that a trained legal eye has searched the record for arguable issues and assists the reviewing court in its own evaluation of the case.
Finally, an additional flaw with the procedures in Eskridge and Lane was that there was only one tier of review—by the trial judge in Eskridge (who understandably had little incentive to find any error warranting an appeal) and by the public defender in Lane. See Anders, supra, at 742-743. The procedure in Douglas itself was, in part, flawed for the same reason. See 372 U. S., at 354-355. The Wende procedure, of course, does not suffer from this flaw, for it provides at least two tiers of review.
Not only does the Wende procedure far exceed those procedures that we have found invalid, but it is also at least comparable to those procedures that we have approved. Turning first to the procedure we set out in the final section of Anders, we note that it has, from the beginning, faced " 'consistent and severe criticism.' " In re Sade C., 13 Cal. 4th 952, 979, n. 7, 920 P. 2d 716, 731, n. 7 (1996) (quoting Note, 67 Texas L. Rev. 181, 212 (1988)). One of the most consistent criticisms, one with which we wrestled in McCoy, is that Anders is in some tension both with counsel's ethical duty as an officer of the court (which requires him not to present frivolous arguments) and also with his duty to further his client's interests (which might not permit counsel to characterize his
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