Zack Park was working as a shift supervisor at a Sheetz store. At about 10:30 p.m., Park noticed the defendant, who had been standing next to a merchandise rack for about 30-45 minutes. Defendant was studying a rack of prepaid bank/merchandise cards and writing things down on a notepad. Earlier, defendant had asked if he could take pictures of the cards, but was told no due to store policy. Ultimately, Park told defendant he would have to leave the store if he was not going to buy anything. Defendant said he was going to buy a lot of things, and then continued to linger around the card rack. Park told defendant that Sheetz had a no-loitering policy and asked him to leave several times, but defendant refused. Park contacted store security and then the police. Police asked defendant to leave several times but defendant refused. Eventually, police escorted defendant out of the store and later arrested him after he refused to leave the premises. Defendant was convicted of defiant trespass. He appealed. The appellate court considered counsel's petition for leave to withdraw as defendant's attorney and brief pursuant to Anders v California, 386 U.S. 738 (1967). Counsel satisfied all the technical requirements for a petition to withdraw set forth in Anders. Thus, the court considered the issues raised on appeal. At trial, defendant sought to introduce the testimony of his sister, Jamie Moore, who would testify that defendant frequently purchased prepaid electronic cards of the kind he was examining at Sheetz. Moore testified that defendant had a habit of being very meticulous when he made such purchases and taking an inordinate amount of time examining items for sale. The trial court opined that Moore's proffered testimony was irrelevant and, therefore, denied defendant's request to call her as a witness. On appeal, defendant argued that the trial court erred in denying this testimony, while counsel claimed in his petition to withdraw that the appeal was wholly frivolous. The issue defendant raised was not so lacking in merit that counsel should be permitted to withdraw, the court concluded. Sheetz's no-loitering policy included customers who were at the location “without a legitimate purpose.” Moore's proffered testimony that defendant had a habit of buying prepaid cards and was a meticulous shopper who took an inordinate amount of time to make purchases would support a defense that defendant had a legitimate purpose for remaining on the premises, the court reasoned. The testimony could have explained why defendant was staring at the card rack for so long. Moreover, such evidence could have bolstered the defense argument that this case boiled down to someone taking too long to make a purchase and did not fit within the store's own definition of loitering. In fact, Park conceded that the store's no-loitering policy was “kind of vague.” Accordingly, the court remanded with instructions for counsel to file an advocate's brief.