20/02/2026
Phillips Black spent 2 years collecting and studying Finley “no-merit” letters in Pennsylvania. The recipients were 100% poor and over 80% people of color.
We found sweeping ethical violations. More than 1/3 violated the duty of confidentiality and/or the attorney-client privilege. 1/4 disclosed information Finley-filers learned directly from their clients. Almost 2/3 disparaged or showed mistrust of clients, and nearly all displayed deficient factual and legal engagement.
Pennsylvania leads the country in sentences of life without the possibility of parole (LWOP). And Philadelphia has sentenced more individuals to die in prison than any county in the country — 84% are Black, and 50% were under the age of 25 at the time of the offense.
Finley letters allow a lawyer to move to withdraw from the representation by arguing that all their client’s claims lack merit in a publicly filed “no-merit” letter.
Despite the frequency of Finley letters in post-conviction cases, no empirical data about Finley “no-merit” letters has previously been collected. To begin filling this gap, Phillips Black collected 335 Finley “no-merit” letters from across Pennsylvania and analyzed how the procedure functioned in each case. A subset of 100 Finley letters filed in Philadelphia homicide cases involving LWOP sentences was more closely reviewed for insight into ethical issues and the quality of legal analysis.
Read the full Finley Report at phillipsblack.org/finleyreport. Link in bio!
