Anders brief (North Carolina) · Go Syfert
← North Carolina issues

Anders brief in North Carolina

23 North Carolina opinions name it 2 courts 1994–2025 6 in the last five years

The cases below were cited by North Carolina courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (20)

CaseFollowedCited
Anders v. Californiagreen
scotus · 1967 · cited in 16 North Carolina opinions naming this issue, 1994–2024
2 sentences

2024WALKER Opinion of the Court an Anders brief, see Anders v. California, 386 U.S. 738 (1967), and the Court of Appeals found no error at trial.

2018The concept of a no-merit brief, also referred to as an Anders brief, comes from the United States Supreme Court's decision in Anders v. California , 386 U.S. 738 , 87 S.Ct. 1396 , 18 L.Ed.2d 493 (1967).

616
Denise H. v. Arizona Department of Economic Securitygreen
arizctapp · 1998 · cited in 4 North Carolina opinions naming this issue, 2000–2018
2 sentences

2018This Court decided to adopt what it then considered to be the "majority rule," and directly adopted the reasoning from an Arizona opinion, concluding that " 'counsel for a parent appealing from a juvenile court's severance order has no right to file an Anders brief.' " Id. at 833 , 526 S.E.2d at 503 (quoting Denise H. v. Arizona Dept. of Economic Sec. , 193 Ariz. 257 , 259, 972 P.2d 241 , 243 (1998) ).

2018This Court decided to adopt what it then considered to be the "majority rule," and directly adopted the reasoning from an Arizona opinion, concluding that " 'counsel for a parent appealing from a juvenile court's severance order has no right to file an Anders brief.' " Id. at 833 , 526 S.E.2d at 503 (quoting Denise H. v. Arizona Dept. of Economic Sec. , 193 Ariz. 257 , 259, 972 P.2d 241 , 243 (1998) ).

34
In Re Harrisongreen
ncctapp · 2000 · cited in 3 North Carolina opinions naming this issue, 2007–2018
2 sentences

2018In deciding not to extend Anders protections to appeals from TPR orders, this Court in Harrison reasoned: " 'An attorney for a criminal defendant who believes that his client's appeal is without merit is permitted to file what has become known as an Anders brief.' However, this jurisdiction has not extended the procedures and protections afforded in Anders and Kinch to civil cases." Id. at 832, 526 S.E.2d at 502 (citation omitted). 8 In support of our decision not to extend Anders protections to TPR cases, this Court in Harrison noted: "The majority of states who have addressed this issue have

2018This Court decided to adopt what it then considered to be the "majority rule," and directly adopted the reasoning from an Arizona opinion, concluding that " 'counsel for a parent appealing from a juvenile court's severance order has no right to file an Anders brief.' " Id. at 833 , 526 S.E.2d at 503 (quoting Denise H. v. Arizona Dept. of Economic Sec. , 193 Ariz. 257 , 259, 972 P.2d 241 , 243 (1998) ).

33
In Re Maygreen
ncctapp · 2002 · cited in 3 North Carolina opinions naming this issue, 2007–2018
2 sentences

2018App. 299 , 301, 569 S.E.2d 704 , 707 (2002) ("an attorney for an indigent juvenile adjudicated to be delinquent may file an Anders brief in the appellate courts of this state").

2018App. 299, 301 , 569 S.E.2d 704, 707 (2002) (“an attorney for an indigent juvenile adjudicated to be delinquent may file an Anders brief in the appellate courts of this state”).

23
State v. Kinchgreen
nc · 1985 · cited in 4 North Carolina opinions naming this issue, 2000–2012
2 sentences

2007Pursuant to Anders v. California, 386 U.S. 738 , 87 S.Ct. 1396 , 18 L.Ed.2d 493 (1967), and State v. Kinch, 314 N.C. 99 , 331 S.E.2d 665 (1985), the juvenile's appellate counsel has filed a brief in which he represents that he "is unable to identify any issue with sufficient merit to support a meaningful argument for relief on appeal" and asks that we "conduct a full examination of the record in this case for possible prejudicial error." See also In re May, 153 N.C.App. 299, 301 , 569 S.E.2d 704, 707 (2002) (holding that "an attorney for an indigent juvenile adjudicated to be delinquent may fi

2007Pursuant to Anders v. California, 386 U.S. 738 , 87 S.Ct. 1396 , 18 L.Ed.2d 493 (1967), and State v. Kinch, 314 N.C. 99 , 331 S.E.2d 665 (1985), the juvenile's appellate counsel has filed a brief in which he represents that he "is unable to identify any issue with sufficient merit to support a meaningful argument for relief on appeal" and asks that we "conduct a full examination of the record in this case for possible prejudicial error." See also In re May, 153 N.C.App. 299, 301 , 569 S.E.2d 704, 707 (2002) (holding that "an attorney for an indigent juvenile adjudicated to be delinquent may fi

14
LC v. Stategreen
utahctapp · 1998 · cited in 3 North Carolina opinions naming this issue, 2000–2007
2 sentences

2007Dept. v. Alicia P., 127 N.M. 664 , 986 P.2d 460, 462 (1998) (holding the Anders procedure to be applicable in an appeal of an order terminating parental rights); L.C. v. State, 963 P.2d 761, 764 (Utah App. 1998), cert. denied, D.C. v. State, 982 P.2d 88 (Utah 1999) (holding that appointed counsel may file an Anders brief when representing an indigent client in a termination of parental rights appeal); J.K. v. Lee County, 668 So.2d 813, 816 (Ala.Civ.App.1995) (extending the procedures set forth in Anders to "civil cases in which an indigent client has a court-appointed attorney as authorized by

2007Dept. v. Alicia P., 127 N.M. 664 , 986 P.2d 460 , 462 (1998) (holding the Anders procedure to be applicable in an appeal of an order terminating parental rights); L.C. v. State, 963 P.2d 761 , 764 (Utah App. 1998), cert. denied, D.C. v. State, 982 P.2d 88 (Utah 1999) (holding that appointed counsel may file an Anders brief when representing an indigent client in a termination of parental rights appeal); J.K. v. Lee County, 668 So.2d 813 , 816 (Ala.Civ.App.1995) (extending the procedures set forth in Anders to "civil cases in which an indigent client has a court-appointed attorney as authorized

13
In Re VEgreen
pasuperct · 1992 · cited in 2 North Carolina opinions naming this issue, 2007–2007
2 sentences

2007LEXIS 2558 (Conn.Super.Ct.1994) (finding the Anders procedure appropriate if appeal of an order terminating parental rights is sought); In re V.E., 417 Pa.Super. 68 , 611 A.2d 1267, 1275 (1992) (permitting an appointed attorney to withdraw from an appeal of a termination order only after following the Anders procedure); Morris v. Lucas County Children Serv.

2007LEXIS 2558 (Conn.Super.Ct.1994) (finding the Anders procedure appropriate if appeal of an order terminating parental rights is sought); In re V.E., 417 Pa.Super. 68 , 611 A.2d 1267, 1275 (1992) (permitting an appointed attorney to withdraw from an appeal of a termination order only after following the Anders procedure); Morris v. Lucas County Children Serv.

12
State Ex Rel. Children, Youth & Families Department v. Alicia P.green
nmctapp · 1998 · cited in 2 North Carolina opinions naming this issue, 2007–2007
2 sentences

2007Dept. v. Alicia P., 127 N.M. 664 , 986 P.2d 460, 462 (1998) (holding the Anders procedure to be applicable in an appeal of an order terminating parental rights); L.C. v. State, 963 P.2d 761, 764 (Utah App. 1998), cert. denied, D.C. v. State, 982 P.2d 88 (Utah 1999) (holding that appointed counsel may file an Anders brief when representing an indigent client in a termination of parental rights appeal); J.K. v. Lee County, 668 So.2d 813, 816 (Ala.Civ.App.1995) (extending the procedures set forth in Anders to "civil cases in which an indigent client has a court-appointed attorney as authorized by

2007Dept. v. Alicia P., 127 N.M. 664 , 986 P.2d 460, 462 (1998) (holding the Anders procedure to be applicable in an appeal of an order terminating parental rights); L.C. v. State, 963 P.2d 761, 764 (Utah App. 1998), cert. denied, D.C. v. State, 982 P.2d 88 (Utah 1999) (holding that appointed counsel may file an Anders brief when representing an indigent client in a termination of parental rights appeal); J.K. v. Lee County, 668 So.2d 813, 816 (Ala.Civ.App.1995) (extending the procedures set forth in Anders to "civil cases in which an indigent client has a court-appointed attorney as authorized by

12
JK v. Lee County Dept. of Human Resourcesgreen
alacivapp · 1995 · cited in 2 North Carolina opinions naming this issue, 2007–2007
2 sentences

2007Dept. v. Alicia P., 127 N.M. 664 , 986 P.2d 460, 462 (1998) (holding the Anders procedure to be applicable in an appeal of an order terminating parental rights); L.C. v. State, 963 P.2d 761, 764 (Utah App. 1998), cert. denied, D.C. v. State, 982 P.2d 88 (Utah 1999) (holding that appointed counsel may file an Anders brief when representing an indigent client in a termination of parental rights appeal); J.K. v. Lee County, 668 So.2d 813, 816 (Ala.Civ.App.1995) (extending the procedures set forth in Anders to "civil cases in which an indigent client has a court-appointed attorney as authorized by

2007Dept. v. Alicia P., 127 N.M. 664 , 986 P.2d 460 , 462 (1998) (holding the Anders procedure to be applicable in an appeal of an order terminating parental rights); L.C. v. State, 963 P.2d 761 , 764 (Utah App. 1998), cert. denied, D.C. v. State, 982 P.2d 88 (Utah 1999) (holding that appointed counsel may file an Anders brief when representing an indigent client in a termination of parental rights appeal); J.K. v. Lee County, 668 So.2d 813 , 816 (Ala.Civ.App.1995) (extending the procedures set forth in Anders to "civil cases in which an indigent client has a court-appointed attorney as authorized

12
Potter v. Californiagreen
scotus · 1967 · cited in 2 North Carolina opinions naming this issue, 1994–1998
2 sentences

1998Ed. 2d 493 , reh’g denied, 388 U.S. 924 , 18 L.

1994See Anders v. California, 386 U.S. 738 , 87 S.Ct. 1396 , 18 L.Ed.2d 493 , reh'g denied, 388 U.S. 924 , 87 S.Ct. 2094 , 18 L.Ed.2d 1377 (1967).

12
O'Bryan v. Chandlergreen
scotus · 1967 · cited in 2 North Carolina opinions naming this issue, 1994–1998
2 sentences

1998Ed. 2d 493 , reh’g denied, 388 U.S. 924 , 18 L.

1994See Anders v. California, 386 U.S. 738 , 87 S.Ct. 1396 , 18 L.Ed.2d 493 , reh'g denied, 388 U.S. 924 , 87 S.Ct. 2094 , 18 L.Ed.2d 1377 (1967).

12
In re L.E.M.green
nc · 2019 · cited in 1 North Carolina opinions naming this issue, 2025–2025
1 sentence

2025In re L.E.M., 372 N.C. 396, 402 (2019). -5- IN RE: W.G.T., M.V.T.

11
State v. Nevillsgreen
ncctapp · 2003 · cited in 1 North Carolina opinions naming this issue, 2024–2024
1 sentence

2024Ct. App. June 2, 2020) (unpublished) (reviewing an Anders brief after the defendant entered an open plea); State v. Nevills, 158 N.C.

11
In re N.B.green
ncctapp · 2007 · cited in 1 North Carolina opinions naming this issue, 2018–2018
1 sentence

2018We can find no case in which 10 Although the holding in Harrison has been characterized as one denying Anders review in civil cases, see In re N.B., N.B., J.B., N.B., & J.B., 183 N.C.

11
In Re DESgreen
texapp · 2004 · cited in 1 North Carolina opinions naming this issue, 2018–2018
2 sentences

2018In re D.E.S. , 135 S.W.3d 326 , 329 (Tex. App.-14th Dist. 2004) (citations omitted).

2018In re D.E.S., 135 S.W.3d 326, 329 (Tex. App. – 14th Dist. 2004) (citations omitted).

11
Kent v. United Statesgreen
scotus · 1966 · cited in 1 North Carolina opinions naming this issue, 2002–2002
2 sentences

2002Although a juvenile delinquency proceeding is not for all purposes treated as a criminal proceedings, the United States Supreme Court has held a juvenile alleged to be delinquent is entitled to "the essentials of due process." Kent v. United States, 383 U.S. 541, 562 , 86 S.Ct. 1045, 1058 , 16 L.Ed.2d 84, 97-98 (1966).

2002Although a juvenile delinquency proceeding is not for all purposes treated as a criminal proceedings, the United States Supreme Court has held a juvenile alleged to be delinquent is entitled to "the essentials of due process." Kent v. United States, 383 U.S. 541, 562 , 86 S.Ct. 1045, 1058 , 16 L.Ed.2d 84, 97-98 (1966).

11
State v. Mayfieldgreen
ncctapp · 1994 · cited in 1 North Carolina opinions naming this issue, 2000–2000
2 sentences

2000“An attorney for a criminal defendant who believes that his client’s appeal is without merit is permitted to file what has become known as an Anders brief.” State v. Mayfield, 115 N.C.

2000App. 725, 726 , 446 S.E.2d 150, 152 (1994) (emphasis added).

11
DCFS v. Natural Parents of JBgreen
fladistctapp · 1999 · cited in 1 North Carolina opinions naming this issue, 2000–2000
1 sentence

2000See Department of Children and Family Services v. Natural Parents of J.B., 736 So.2d 111, 114 (Fla. App. 1999) (Anders procedures do not apply in termination of parental rights cases); County of Kern v. Dillier, 69 Cal. App. 4th 1412, 1419 , 82 Cal. Rptr. 2d 318, 322 (1999) (‘Anders’s ‘prophylactic’ procedures are designed solely to protect the indigent criminal defendant’s right, under the Fourteenth Amendment’s due process and equal protection clauses, to the assistance of appellate counsel appointed by the state”); Denise H. v. Arizona Dept. of Economic Sec., 193 Ariz. 257, 259 , 972 P.2d 2

11
County of Kern v. Dilliergreen
calctapp · 1999 · cited in 1 North Carolina opinions naming this issue, 2000–2000
2 sentences

2000See Department of Children and Family Services v. Natural Parents of J.B., 736 So.2d 111, 114 (Fla. App. 1999) (Anders procedures do not apply in termination of parental rights cases); County of Kern v. Dillier, 69 Cal. App. 4th 1412, 1419 , 82 Cal. Rptr. 2d 318, 322 (1999) (‘Anders’s ‘prophylactic’ procedures are designed solely to protect the indigent criminal defendant’s right, under the Fourteenth Amendment’s due process and equal protection clauses, to the assistance of appellate counsel appointed by the state”); Denise H. v. Arizona Dept. of Economic Sec., 193 Ariz. 257, 259 , 972 P.2d 2

2000See Department of Children and Family Services v. Natural Parents of J.B., 736 So.2d 111, 114 (Fla. App. 1999) (Anders procedures do not apply in termination of parental rights cases); County of Kern v. Dillier, 69 Cal. App. 4th 1412, 1419 , 82 Cal. Rptr. 2d 318, 322 (1999) (‘Anders’s ‘prophylactic’ procedures are designed solely to protect the indigent criminal defendant’s right, under the Fourteenth Amendment’s due process and equal protection clauses, to the assistance of appellate counsel appointed by the state”); Denise H. v. Arizona Dept. of Economic Sec., 193 Ariz. 257, 259 , 972 P.2d 2

11
New York Central R. Co. v. United Statesgreen
scotus · 1967 · cited in 1 North Carolina opinions naming this issue, 1994–1994
1 sentence

1994See Anders v. California, 386 U.S. 738 , 87 S.Ct. 1396 , 18 L.Ed.2d 493 , reh'g denied, 388 U.S. 924 , 87 S.Ct. 2094 , 18 L.Ed.2d 1377 (1967).

11

Distinguished, questioned or overruled (2)

CaseNegativeCited
LC v. Stategreen
utahctapp · 1998 · cited in 3 North Carolina opinions naming this issue, 2000–2007
2 sentences

2007Dept. v. Alicia P., 127 N.M. 664 , 986 P.2d 460, 462 (1998) (holding the Anders procedure to be applicable in an appeal of an order terminating parental rights); L.C. v. State, 963 P.2d 761, 764 (Utah App. 1998), cert. denied, D.C. v. State, 982 P.2d 88 (Utah 1999) (holding that appointed counsel may file an Anders brief when representing an indigent client in a termination of parental rights appeal); J.K. v. Lee County, 668 So.2d 813, 816 (Ala.Civ.App.1995) (extending the procedures set forth in Anders to "civil cases in which an indigent client has a court-appointed attorney as authorized by

2007Dept. v. Alicia P., 127 N.M. 664 , 986 P.2d 460 , 462 (1998) (holding the Anders procedure to be applicable in an appeal of an order terminating parental rights); L.C. v. State, 963 P.2d 761 , 764 (Utah App. 1998), cert. denied, D.C. v. State, 982 P.2d 88 (Utah 1999) (holding that appointed counsel may file an Anders brief when representing an indigent client in a termination of parental rights appeal); J.K. v. Lee County, 668 So.2d 813 , 816 (Ala.Civ.App.1995) (extending the procedures set forth in Anders to "civil cases in which an indigent client has a court-appointed attorney as authorized

13
L.C. v. Stateyellow
utahctapp · 1998 · cited in 1 North Carolina opinions naming this issue, 2000–2000
1 sentence

2000But see L.C. v. State, 963 P.2d 761 , 348 Utah Adv.

11

Also cited on this issue (7)

CaseCitedYears
State v. Grundler green
nc · 1959
2 sentences

2022Grundler, 251 N.C. at 189 , 111 S.E.2d at 9 . ¶ 24 This issue should have presented to this Court, if at all under an Anders brief.

2022Grundler, 251 N.C. at 189 , 111 S.E.2d at 9 . ¶ 24 This issue should have presented to this Court, if at all under an Anders brief.

22022–2022
In Re May green
nc · 2003
2 sentences

2007Pursuant to Anders v. California, 386 U.S. 738 , 87 S.Ct. 1396 , 18 L.Ed.2d 493 (1967), and State v. Kinch, 314 N.C. 99 , 331 S.E.2d 665 (1985), the juvenile's appellate counsel has filed a brief in which he represents that he "is unable to identify any issue with sufficient merit to support a meaningful argument for relief on appeal" and asks that we "conduct a full examination of the record in this case for possible prejudicial error." See also In re May, 153 N.C.App. 299, 301 , 569 S.E.2d 704, 707 (2002) (holding that "an attorney for an indigent juvenile adjudicated to be delinquent may fi

2007Pursuant to Anders v. California, 386 U.S. 738 , 87 S.Ct. 1396 , 18 L.Ed.2d 493 (1967), and State v. Kinch, 314 N.C. 99 , 331 S.E.2d 665 (1985), the juvenile's appellate counsel has filed a brief in which he represents that he "is unable to identify any issue with sufficient merit to support a meaningful argument for relief on appeal" and asks that we "conduct a full examination of the record in this case for possible prejudicial error." See also In re May, 153 N.C.App. 299, 301 , 569 S.E.2d 704, 707 (2002) (holding that "an attorney for an indigent juvenile adjudicated to be delinquent may fi

22007–2007
In Re NB green
ncctapp · 2007
2 sentences

2018This meant that "counsel for a parent appealing an order terminating parental rights did not have a right to file an Anders brief." Id.

2018But we "urge[d] our Supreme Court or the General Assembly to reconsider this issue." Id.

12018–2018
McCoy v. Court of Appeals of Wisconsin, District 1 green
scotus · 1988
2 sentences

2018The entire purpose of the Anders brief and the court's "independent review" of the record (the Anders opinion doesn't actually call it that) is to assist the court "in making the critical determination whether the appeal is indeed so frivolous that counsel should be permitted to withdraw." McCoy v. Court of Appeals of Wisconsin , 486 U.S. 429 , 439, 108 S.Ct. 1895 , 100 L.Ed.2d 440 (1988).

2018The entire purpose of the Anders brief and the court's "independent review" of the record (the Anders opinion doesn't actually call it that) is to assist the court "in making the critical determination whether the appeal is indeed so frivolous that counsel should be permitted to withdraw." McCoy v. Court of Appeals of Wisconsin , 486 U.S. 429 , 439, 108 S.Ct. 1895 , 100 L.Ed.2d 440 (1988).

12018–2018
Knight v. Wal-Mart Stores, Inc. green
ncctapp · 2002
1 sentence

2017"An employee seeking indemnity benefits pursuant to the Workers' Compensation Act has, at the outset, two very general options." Knight v. Wal-Mart Stores, Inc., 149 N.C.

12017–2017
In Re GAULT green
scotus · 1967
1 sentence

2002II The Anders court held that a copy of the "counsel's brief should be furnished the indigent and time allowed [her] to raise any points that [she] chooses." Anders, 386 U.S. at 744 , 87 S.Ct. at 1400 , 18 L.Ed.2d at 498 .

12002–2002
State v. Bennett green
ncctapp · 1991
2 sentences

1998State v. Bennett, 102 N.C.

1998App. 797 , 404 S.E.2d 4 (1991) (sanctioning defendant’s counsel for failure to file a complete record with his Anders brief); see also Anders v. California, 386 U.S. 738 , 18 L.

11998–1998

Statutes the citing opinions construe

NC § N.C. Gen. Stat. § 15A-1444 (5) NC § N.C. Gen. Stat. § 15A-979 (5) NC § N.C. Gen. Stat. § 7B-1001 (4) NC § N.C. Gen. Stat. § 15A-1022 (3) NC § N.C. Gen. Stat. § 7A-32 (3) NC § N.C. Gen. Stat. § 7B-100 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

TX 5327 (1925–2026) PA 2839 (1970–2026) OH 509 (1994–2026) LA 346 (1995–2025) NY 157 (1989–2026) FL 125 (1972–2026) CA 65 (1992–2026) IL 64 (1973–2026) AZ 56 (1970–2022) AR 54 (2001–2026) KY 34 (2001–2026) WA 29 (1969–2024) NC 23 (1994–2025) UT 21 (1978–2023) CT 21 (1986–2019) GA 19 (1978–2022) MT 15 (1992–2025) WY 14 (1989–2023) AL 10 (1986–2015) SC 9 (2002–2024) OR 6 (1984–2025) IN 6 (1972–2026) VT 5 (2005–2014) MI 4 (1984–2022) CO 4 (2006–2010) WI 4 (1974–2001) AK 3 (1988–2023) DC 3 (1981–2026) TN 3 (1997–2000) SD 2 (2004–2015) HI 2 (1996–2001) IA 2 (2021–2021) ND 2 (2020–2020) VA 2 (2003–2022)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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