In Anders v. California, 386 U.S. 738 (1967), the attorney performed a conscientious evaluation of the merits of the defendant's appeal finding that there were none. The attorney submitted a "no-issue letter" to the court pursuing no further appeal. The Supreme Court criticized the attorney's actions, finding that the attorney had acted more as amicus curiae rather than active advocate. The Court held that "the constitutional requirement of substantial equality and fair process can only be attained where counsel acts in the role of an active advocate in behalf of his client. . . ." Id. 386 U.S. at 744, 87 S. Ct. at 1400. The Court held: If counsel finds his case to be wholly frivolous, after a conscientious examination of it, he should so advise the court and request permission to withdraw. That request must, however, be accompanied by a brief referring to anything in the record that might arguably support the appeal. A copy of counsel's brief should be furnished to the indigent and time allowed him to raise any points that he chooses; the court - not counsel - then proceeds, after full examination of all the proceedings, to decide whether the case is wholly frivolous. Id. at 744-45; 87 S. Ct. at 1400. The Supreme Court struck down a California procedure that allowed the indigent's attorney "to withdraw upon filing a conclusory letter stating that the appeal had 'no merit' and that permitted the appellate court to affirm the indigent's conviction . . . if, following . . . its own review of the record," the appellate court reached the same conclusion. In place of this procedure, the Supreme Court suggested a substitute procedure that would satisfy the Constitution's command: The attorney's request to withdraw must . . . be accompanied by a brief referring to anything in the record that might arguably support the appeal. A copy of counsel's brief should be furnished to the indigent and time should be allowed for him to raise any points that he chooses; the court--not counsel -- then proceeds, after a full examination of all the proceedings, to decide whether the case is wholly frivolous. (Anders, 386 U.S. at 744.) In Anders, the United States Supreme Court adopted a procedure to protect an indigent litigant's right to counsel on appeal -- a procedure designed to ensure that an indigent's appeal receives fair and meaningful evaluation, based on the merits of the case, before a court allows the appeal to be dismissed as frivolous. The United States Supreme Court held that if counsel, after a conscientious examination of the case, determines it to be wholly frivolous he should so advise the court and request permission to withdraw. Id. at 744. This request, however, must be accompanied by a brief identifying anything in the record that could arguably support the appeal. Id. Counsel must also furnish his client with a copy of the brief and request to withdraw and allow the client sufficient time to raise any matters that he chooses. Id. Once these requirements have been satisfied, the appellate court must then conduct a full examination of the proceedings held below to determine if the appeal is indeed frivolous. If the appellate court determines that the appeal is frivolous, it may grant counsel's request to withdraw and dismiss the appeal without violating constitutional requirements or may proceed to a decision on the merits if state law so requires. Id. The United States Supreme Court held that a court-appointed defense attorney in a criminal case who determines, after fully examining the record, that an appeal is wholly frivolous and without merit must so advise the appellate court and then set forth any potential points of error and applicable law that might arguably support the appellant's position. Several of our sister courts of appeals have acknowledged that Anders briefs may be appropriate in parental termination cases. See: (1) In re D.E.S., 135 S.W.3d 326, 329 (Tex. App.--Houston 14th Dist. 2004, no pet.); (2) In re K.D., 127 S.W.3d 66, 67 (Tex. App.--Houston 1st Dist. 2003, no pet.); (3) Porter v. Texas Dep't of Protective & Regulatory Servs., 105 S.W.3d 52, 56 (Tex. App.--Corpus (4) Christi 2003, no pet.); (5) In re K.M., 98 S.W.3d 774, 777 (Tex. App.--Fort Worth 2003, no pet.); (6) In re E.L.Y., 69 S.W.3d 838, 841 (Tex. App.--Waco 2002, no pet.); (7) In re A.W.T., 61 S.W.3d 632, 634 (Tex. App.--Tyler 2001, no pet.). In sun, the United States Supreme Court held that if counsel, after a conscientious examination of the case, determines it to be wholly frivolous he should so advise the court and request permission to withdraw. 386 U.S. at 744. See, also, State v. Duncan (1978), 57 Ohio App.2d 93, 385 N.E.2d 323. This request, however, must be accompanied by a brief identifying anything in the record that could arguably support the appeal. Id. Counsel must also furnish his client with a copy of the brief and request to withdraw and allow the client sufficient time to raise any matters that he chooses. Id. Once these requirements have been satisfied, the appellate court must then conduct a full examination of the proceedings held below to determine if the appeal is indeed frivolous. If the appellate court determines that the appeal is frivolous, it may grant counsel's request to withdraw and dismiss the appeal without violating constitutional requirements or may proceed to a decision on the merits if state law so requires. Id. In Anders, the United States Supreme Court held if, after a conscientious examination of the record, a defendant's counsel concludes the case is wholly frivolous, then he should so advise the court and request permission to withdraw. Id. at 744. Counsel must accompany his request with a brief identifying anything in the record that could arguably support his client's appeal. Id. Counsel also must: (1) furnish his client with a copy of the brief and request to withdraw; and; (2) allow his client sufficient time to raise any matters that the client chooses. Id. Once the defendant's counsel satisfies these requirements, the appellate court must fully examine the proceedings below to determine if any arguably meritorious issues exist. If the appellate court also determines that the appeal is wholly frivolous, it may grant counsel's request to withdraw and dismiss the appeal without violating constitutional requirements, or may proceed to a decision on the merits if state law so requires. Id. The United States Supreme Court held that if counsel, after a conscientious examination of the case, determines it to be wholly frivolous he should so advise the court and request permission to withdraw. Id. at 744. This request, however, must be accompanied by a brief identifying anything in the record that could arguably support the appeal. Id. Counsel must also furnish his client with a copy of the brief and request to withdraw and allow the client sufficient time to raise any matters that he chooses. Id. Once these requirements have been satisfied, the appellate court must then conduct a full examination of the proceedings held below to determine if the appeal is indeed frivolous. If the appellate court determines that the appeal is frivolous, it may grant counsel's request to withdraw and dismiss the appeal without violating constitutional requirements or it may proceed to a decision on the merits if state law so requires. Id. The United States Supreme Court held that if, after a conscientious examination of the record, a defendant's counsel concludes that the case is wholly frivolous, he should so advise the court and request permission to withdraw. Id. at 744. Counsel must accompany his request with a brief identifying anything in the record that could arguably support his client's appeal. Id. Counsel also must: (1) furnish his client with a copy of the brief and request to withdraw; and; (2) allow his client sufficient time to raise any matters that the client chooses. Id.