Under People v. Wende (1979), a defense attorney’s determination that an appeal from a conviction is meritless triggers an appellate court duty to itself review the entire record to verify the appeal is frivolous. In People v. Delgadillo, the Supreme Court today says there is no such requirement when an appeal from the denial of certain postconviction relief “does not implicate a constitutional right to counsel.” That is true “even if the defendant has a state-created right to the appointment of counsel for that appeal,” the court says.