Frankhouser v. Pennsylvania Board of Probation & Parole

CRAIG, President Judge.

The Allegheny County Public Defender’s Office seeks to withdraw as appointed counsel for the petitioner, Robert Frankhouser. In order to review this request, we shall first address the applicable standards for withdrawal and then the merits of the petition for review.

Before our Supreme Court’s decision in Commonwealth v. Turner, 518 Pa. 491, 544 A.2d 927 (1988), counsel appointed to represent an indigent accused was required to satisfy the rigorous requirements of Anders v. California, 386 U.S. 738, 87 S.Ct. 1396, 18 L.Ed.2d 493 (1967) and Commonwealth v. McClendon, 495…