Com. v. Fink, A.

Superior Court of Pennsylvania·Decided August 24, 2026·No. 968 MDA 2025·Unpublished·Olson

Opinion

NON-PRECEDENTIAL DECISION - SEE SUPERIOR COURT O.P. 65.37

COMMONWEALTH OF PENNSYLVANIA : IN THE SUPERIOR COURT OF : PENNSYLVANIA

:

v. :

:

:

ADAM DOUGLAS FINK :

:

Appellant : No. 968 MDA 2025

Appeal from the Judgment of Sentence Entered June 24, 2025 In the Court of Common Pleas of Mifflin County Criminal Division at No(s): CP-44-CR-0000396-2023

BEFORE: BOWES, J., OLSON, J., and KUNSELMAN, J. MEMORANDUM BY OLSON, J.: FILED: AUGUST 24, 2026 Appellant, Adam Douglas Fink, appeals from the June 24, 2025 judgment of sentence entered in the Court of Common Pleas of Mifflin County after a jury convicted him of discharge of a firearm into an occupied structure (Count 2), firearm arms not to be carried without a license (Count 3), and recklessly endangering another person (Count 4).1 The trial court sentenced Appellant to an aggregate term of 84 to 168 months’ incarceration to be followed by one year of reentry supervision.2 Counsel for Appellant, Justin P.

1 18 Pa.C.S.A. §§ 2707.1(a), 6106(a)(1), and 2705, respectively.

2 On Count 2, the trial court sentenced Appellant to 42 to 84 months’ incarceration and awarded Appellant 720 days credit for time served. Appellant was ordered to pay a $500.00 fine and restitution in the amount of $3,779.73.

Miller, Esquire (“Attorney Miller”) filed an Anders brief and a petition to withdraw as counsel.3 Upon review, we affirm the judgment of sentence and grant the petition to withdraw.

Appellant’s criminal conviction stems from an incident on October 25, 2022, wherein Appellant, armed with a handgun, shot at, and struck, a residence while the victim was inside sleeping. Affidavit of Probable Cause, 7/6/23. Appellant was charged with the aforementioned crimes, as well as persons not to possess, use, manufacture, control, sell, or transfer firearms (Count 1).4 On May 16, 2025, a jury convicted Appellant of discharge of a firearm into an occupied structure, firearm arms not to be carried without a license, and recklessly endangering another person. On June 24, 2025, the

On Count 3, the trial court sentenced Appellant to 42 to 84 months’ incarceration to be followed by one year of reentry supervision with the sentence set to run consecutively to the sentence imposed on Count 2. Appellant was ordered to pay a $300.00 fine.

On Count 4, the trial court sentenced Appellant to 12 to 24 months’ incarceration with the sentence set to run concurrently to the sentence imposed on Count 2.

Appellant’s aggregate term of incarceration was 84 to 168 months to be followed by one year of reentry supervision. Sentencing Order, 6/27/25.

3 Anders v. California, 386 U.S. 738 (1967); see also Commonwealth v.

Santiago, 978 A.2d 349 (Pa. 2009); Commonwealth v. McClendon, 434 A.2d 1185 (Pa. 1981).

4 18 Pa.C.S.A. § 6105(a)(1). On April 2, 2025, the trial court granted the Commonwealth’s motion to sever Count 1 from the remaining criminal charges.

trial court sentenced Appellant as discussed supra. This appeal followed.5 On March 17, 2026, Attorney Miller filed an Anders brief and a petition to withdraw as counsel with this Court.

Preliminarily, we must address Attorney Miller’s petition to withdraw and the accompanying Anders brief, both alleging this appeal is frivolous and without merit. Anders Brief at 18; see also Petition to Withdraw as Counsel, 3/17/26, at ¶ 2. “When presented with an Anders brief, this Court may not review the merits of the underlying issues without first passing on the request to withdraw.” Commonwealth v. Daniels, 999 A.2d 590, 593 (Pa. Super. 2010) (citation omitted). In order to withdraw pursuant to Anders, “counsel must file a brief that meets the requirements established by our Supreme Court in [Santiago, supra].” Commonwealth v. Harden, 103 A.3d 107, 110 (Pa. Super. 2014) (parallel citation omitted). Specifically, counsel’s Anders brief must comply with the following prerequisites:

(1) provide a summary of the procedural history and facts, with citations to the record;

(2) refer to anything in the record that counsel believes arguably supports the appeal;

(3) set forth counsel’s conclusion that the appeal is frivolous;

and

(4) state counsel’s reasons for concluding that the appeal is frivolous. Counsel should articulate the relevant facts of

5 Appellant and the trial court complied with Pennsylvania Rule of Appellate Procedure 1925.

record, controlling case law, [and] statutes on point that have led to the conclusion that the appeal is frivolous.

Id. (citation omitted).

Pursuant to Commonwealth v. Millisock, 873 A.2d 748 (Pa. Super.

2005), and its progeny, “[c]ounsel also must provide a copy of the Anders brief to his [or her] client.” Commonwealth v. Orellana, 86 A.3d 877, 880 (Pa. Super. 2014) (internal quotation marks and citation omitted). The brief must be accompanied by a letter that advises the client of the option to “(1) retain new counsel to pursue the appeal; (2) proceed pro se on appeal; or (3) raise any points that the appellant deems worthy of [this Court’s] attention in addition to the points raised by counsel in the Anders brief.” Id. “Once counsel has satisfied the above requirements, it is then this Court’s duty to conduct its own review of the trial court’s proceedings and render an independent judgment as to whether the appeal is, in fact, wholly frivolous.” Commonwealth v. Goodwin, 928 A.2d 287, 291 (Pa. Super. 2007) (en banc) (citation and internal quotation marks omitted).

Instantly, Attorney Miller satisfied the technical requirements of Anders and Santiago. In the Anders brief, counsel identifies the pertinent factual and procedural history and makes citation to the record. Counsel raises several issues challenging Appellant’s judgment of sentence that could arguably support an appeal, but ultimately, counsel concludes the appeal is wholly frivolous. Anders Brief at 11-18. Counsel also attached to his petition a letter to Appellant that fulfills the notice requirements of Millisock.

Appellant has not filed a response to counsel’s letter, the Anders brief, or the petition to withdraw. Accordingly, we proceed to conduct an independent review of the record to determine whether the appeal is wholly frivolous.

In the Anders brief, counsel raises the following issues for our review:

1. Whether the trial court violated [Pennsylvania Rule of Criminal Procedure] 600 by trying [Appellant] after more than 365 days not attributable to [Appellant] elapsed?

2. Whether the trial court erred in granting the Commonwealth’s motion to preclude the testimony of [a potential alibi witness] relative to [Appellant’s] alibi defense, thus preventing counsel from eliciting testimony from [the potential alibi witness] regarding the whereabouts of [Appellant] during the time of the alleged criminal acts?

3. Whether the trial court erred in admitting testimony and evidence of a prior trial involving [Appellant] at which he was acquitted?

Anders Brief at 6.6 Appellant’s first issue concerns a potential violation of his right to a speedy trial, as protected by Rule 600, which requires a trial to commence

6 For ease of disposition, we have reorganized Appellant’s issues. The Commonwealth did not file a response brief.

We caution Attorney Miller to carefully review work product submitted to this Court, as well as any court filing. On page 11 of the Anders brief, it appears that Attorney Miller inserted a paragraph concerning another case immediately following his citation to Santiago, supra. See Anders Brief at 11 (referring to the paragraph which starts, “After performing an exhaustive review of the record, . . .”). This error, however, does not affect our assessment of Appellant’s appeal or Attorney Miller’s petition to withdraw.

against a criminal defendant “within 365 days from the date on which the complaint was filed.” Id. at 16-17; see also Pa.R.Crim.P. 600(A)(2)(a).

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