Nov. 14, 2022 – People v. Griffin (4th Dist., Div. 2, E079269)

The Court of Appeal holds that in PC 1172.6 appeals where appointed counsel finds no arguable issues, the court will follow the procedures set out in People v. Wende (1979) 25 Cal.3d 436, including an independent review of the record. The court explains that “the interests of justice call for an independent review of the record as an additional layer of protection from the risk of a defendant remaining unlawfully incarcerated because of a failure to discover a meritorious issue.”

Note: This issue is currently pending in the California Supreme Court in People v. Delgadillo (S266305).