If counsel on appeal on criminal cases consider the appeal frivolous, they must file a brief indicating anything in the record that might arguably support an appeal (Anders v California, 386 U.S. 738 (1967)), or they cannot withdraw. It is called the “Anders Brief”

While the Anders brief is not supposed to create adversity between lawyers and clients, this can certainly happen, as it did in Molina-Martinez v United States, in which the client was ultimately victorious.

For more information, Nathan M. Crystal.