Dansby, Michael Edward Sr., 448 S.W.3d 441

In 2008 Michael Dansby pleaded guilty to indecency with a child and received five years deferred-adjudication community supervision with a general requirement to comply with "sex offender terms and conditions."
The trial court later (outside a formal in‑court hearing) signed a written modification adding specific requirements: take and pass a polygraph "without any admissions" and complete a sex‑offender treatment program; Dansby signed the modification and waived a formal hearing.
During treatment and a polygraph process Dansby refused to answer questions about victims other than the complainant; therapist and polygraph examiner told him to provide only generic/non‑identifying information, but he persisted in refusing.
The State moved to revoke community supervision for refusal to obtain a sexual‑history polygraph and failure to complete treatment; the trial court found the violations true and sentenced Dansby to 18 years.
On initial appeal the Court of Criminal Appeals remanded for consideration of whether Dansby’s discharge from treatment flowed from a valid invocation of the Fifth Amendment; on remand the court of appeals held Dansby forfeited his Fifth Amendment challenge by failing to object when conditions were imposed.
The Court of Criminal Appeals (majority) reversed the court of appeals, holding Dansby was not placed on fair notice that the conditions required him to waive Fifth Amendment protections and therefore did not procedurally forfeit the claim.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether defendant forfeited his Fifth Amendment challenge by failing to object when sex‑offender conditions (including sexual‑history polygraph and treatment) were imposed or modified	Dansby: He lacked fair notice that the conditions would require him to waive his Fifth Amendment right; modification occurred outside a formal hearing and any signed waiver was not shown to be knowing/with counsel present	State: Dansby knew of other victims, was told to comply with sex‑offender conditions, signed modification/consent forms, and statutes/standards describe polygraphs and disclosure in treatment — so he should have objected	Court: Reversed court of appeals — Dansby did not forfeit the Fifth Amendment claim because (1) general on‑the‑record notice of "sex offender conditions" was not specific enough, (2) the modification adding polygraph/treatment was not imposed at a formal hearing giving fair opportunity to object, (3) the phrase "without any admissions" was ambiguous, and (4) signing out‑of‑court forms without counsel does not show a knowing, intelligent waiver of Fifth Amendment rights.

Minnesota v. Murphy, 465 U.S. 420 (U.S. 1984) (Fifth Amendment applies to probationers; limits compelled statements in supervision context)
Garrity v. New Jersey, 385 U.S. 493 (U.S. 1967) (coerced statements in threat of job loss are involuntary and inadmissible)
Kastigar v. United States, 406 U.S. 441 (U.S. 1972) (full use and derivative‑use immunity substitutes for Fifth Amendment privilege)
Speth v. State, 6 S.W.3d 530 (Tex. Crim. App. 1999) (probation conditions are contractual; unobjected conditions may be forfeited if defendant had fair notice)
Chapman v. State, 115 S.W.3d 1 (Tex. Crim. App. 2003) (Fifth Amendment protects probationers from compelled self‑incrimination)
Gutierrez v. State, 380 S.W.3d 167 (Tex. Crim. App. 2012) (waiver/forfeiture principles do not apply to systemic/right‑violating conditions)
Gutierrez‑Rodriguez v. State, 444 S.W.3d 21 (Tex. Crim. App. 2014) (defendant forfeited challenge where restitution condition was discussed at punishment hearing giving opportunity to object)