United States v. Ramirez — dismissed appeal after Anders review found no nonfrivolous issue

Case
United States of America v. David Nanez Ramirez, III
Court
U.S. Court of Appeals for the Fifth Circuit
Judge
Smith; Southwick; Oldham
Date Decided
September 10, 2026
Docket No.
26-10152
Topics
Criminal Appeals; Anders Briefs; Counsel Withdrawal
Source
Read the full opinion

Background

David Nanez Ramirez, III, appealed from proceedings in the U.S. District Court for the Northern District of Texas. The Fifth Circuit resolved the appeal on its summary calendar in an unpublished per curiam opinion.

Ramirez’s appointed attorney moved for leave to withdraw and submitted a brief under Anders v. California, 386 U.S. 738 (1967), and United States v. Flores, 632 F.3d 229 (5th Cir. 2011). Ramirez did not file a response.

The Court’s Holding

The Fifth Circuit reviewed counsel’s brief and the relevant portions of the record identified in it. The court agreed with counsel that the appeal presented no nonfrivolous issue for appellate review.

Accordingly, the court granted counsel’s motion to withdraw, excused counsel from further responsibilities in the case, and dismissed the appeal under Fifth Circuit Rule 42.2.

Key Takeaways

  • An appointed attorney may seek withdrawal by filing an Anders brief when counsel concludes that an appeal presents no nonfrivolous issue.
  • The Fifth Circuit independently reviewed the brief and relevant portions of the record before agreeing with counsel’s assessment.
  • The court granted withdrawal and dismissed the appeal after finding no nonfrivolous appellate issue.

Why It Matters

The opinion illustrates the Fifth Circuit’s procedure for resolving a criminal appeal following an Anders submission. Counsel’s assessment alone did not end the appeal; the panel conducted its own review before permitting withdrawal and dismissing the case.

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