Darius Houston-Randle v. State, 499 S.W.3d 912

Darius Houston-Randle pleaded guilty to aggravated robbery and received deferred adjudication community supervision.
The State filed a motion to adjudicate alleging twelve probation violations; several were abandoned and appellant pleaded not true to the remainder.
At the revocation hearing, victim Andrew Brouchet testified two men (one armed) opened his truck doors, appellant rifled his pockets and demanded money; Brouchet surrendered his wallet and phone because he "really didn’t want to get shot."
The trial court found two allegations true: (1) appellant committed an offense against the State (aggravated robbery—placed victim in fear and exhibited a firearm); and (2) appellant failed to provide medical and mental‑health records to his community supervision officer.
The trial court adjudicated guilt and sentenced appellant to 15 years’ confinement; appellant appealed claiming the revocation was an abuse of discretion as to both findings.
The Court of Appeals affirmed the revocation as modified to correct the judgment (appellant had pled not true, but the judgment incorrectly stated pled true).

Issue	Plaintiff's Argument (State)	Defendant's Argument (Houston-Randle)	Held
1. Whether evidence supported the place‑in‑fear element of aggravated robbery	Victim’s conduct (surrendering property when a gun was present and robber demanded money) shows a reasonable belief of imminent harm; preponderance of credible evidence supports revocation	Brouchet testified he was not afraid; thus no evidence he was placed in fear as required for aggravated robbery	Affirmed — conduct (armed robbery, demand, victim’s statement he gave property to avoid being shot) is more than a scintilla and satisfies place‑in‑fear under preponderance standard
2. Whether revocation was proper for failure to provide medical/mental‑health records	State alleged violation; court found allegation true	Appellant contested the finding	Not reached on merits — court upheld revocation based on the first proved violation; did not decide second allegation

Leonard v. State, 385 S.W.3d 570 (Tex. Crim. App. 2012) (standard of review for revocation of community supervision)
Hacker v. State, 389 S.W.3d 860 (Tex. Crim. App. 2013) (preponderance of evidence standard described and applied)
Jelinek v. Casas, 328 S.W.3d 526 (Tex. 2010) (description of ‘‘more than a scintilla’’ evidentiary threshold)
Howard v. State, 333 S.W.3d 137 (Tex. Crim. App. 2011) (implicit threats can satisfy place‑in‑fear if conduct would reasonably induce compliance)
Cranford v. State, 377 S.W.2d 957 (Tex. Crim. App. 1964) (place‑in‑fear measured by whether defendant’s conduct would induce a person to part with property)
Etzler v. State, 158 S.W.2d 495 (Tex. Crim. App. 1941) (victim need not testify to being scared if conduct and circumstances show reasonable fear)
Devine v. State, 786 S.W.2d 268 (Tex. Crim. App. 1989) (fear must originate from defendant’s conduct, not victim’s temperament)