Epps v. Pennsylvania Board of Probation and Parole

Epps v. Pennsylvania Board of Probation and Parole, 129 Pa. Commw. 240, 565 A.2d 214 (Pa. Cmwlth. 1989), dealt with an appeal from a recommitment order. Epps recognized that counsel seeking to withdraw could file either an Anders brief or a no-merit letter. Epps, 565 A.2d at 216. Unlike the no-merit letter described in Turner, rather than explaining why the petitioner's issues are meritless, Epps stated that such a letter should explain how the petitioner's appeal is "frivolous." Id.