California, United States of America
The following excerpt is from People v. Herrera, B306718 (Cal. App. 2020):
The order before us involves a denial of postconviction relief. We thus have no independent duty to review the record for arguable issues. (People v. Cole (2020) 52 Cal.App.5th 1023, 1034 ["[W]e reject the notion that the Constitution compels the adoption or extension of [People v. Wende (1979) 25 Cal.3d 436] procedures (or any subset of them) for appeals other than a criminal defendant's first appeal of right because, beyond that appeal, there is no right to the effective assistance of counsel."].)2 If a defendant files a supplemental brief, we are "required to evaluate any arguments presented in that brief and to issue a written opinion that disposes of the trial court's order on the merits (that is, by affirming, reversing or other like disposition)." (Cole, at p. 1040.)
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