United States v. Santiago

JOSÉ A. CABRANES, Circuit Judge.

In United States v. Leyba, 379 F.3d 53 (2d Cir.2004), we held that when counsel representing a non-English speaker files a motion to withdraw as counsel on appeal pursuant to Anders v. California, 386 U.S. 738, 87 S.Ct. 1396, 18 L.Ed.2d 493 (1967), he must take reasonable action to ensure that his client received notice of the motion in a language the client understands. United States v. Leyba 379 F.3d at 55-56. Today we address a case in which counsel represents a defendant who may be illiterate.

Defendant-appellant Luis Santiago (“defendant” or “Santiago”)…