Deborah Alford v. State, 13-14-00676-CR

In 2006 Deborah Alford pleaded guilty to delivery of <1 gram of cocaine (state‑jail felony); court imposed 2 years state‑jail sentence, suspended, and 3 years community supervision.
Alford’s supervision was extended multiple times; in October 2014 the State moved to revoke based on alleged violations including positive UA results.
At the November 3, 2014 revocation hearing Alford pleaded "true" to the State’s allegations.
The trial court found the allegations true, revoked community supervision, and sentenced Alford to 2 years in state jail.
Appellate counsel filed an Anders brief and motion to withdraw, asserting no nonfrivolous appellate issues and notifying Alford of her rights; Alford did not file a pro se response raising meritorious issues.
The court conducted an independent review of the record, found no reversible error, affirmed the revocation and granted counsel’s motion to withdraw.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether there were nonfrivolous appellate issues that would warrant reversal of the revocation	Alford (through counsel) implicitly argued there were none by consenting to an Anders brief and not identifying meritorious issues	State argued the revocation was supported by Alford’s plea of true and the record	Court held no reversible error; affirmed revocation and sentence
Whether appellate counsel complied with Anders/Kelly procedural requirements	Counsel contended he complied by filing Anders brief, motion to withdraw, providing records and notifying Alford of rights	State agreed procedural compliance met and no substitute counsel needed	Court held counsel complied with Anders/Kelly and granted withdrawal
Whether an independent review found reversible error under Penson/Anders	Alford did not present additional claims in pro se to challenge the record	State relied on the record and plea to support revocation	Court performed full review, found no reversible error, and affirmed
Whether appellant was properly advised of post‑opinion PDR rights	Counsel asserted he informed Alford of right to file pro se PDR and provided records	State noted no substitute counsel would be appointed and PDR deadlines apply	Court ordered counsel to send opinion/judgment and advise of PDR rights; no appointment of new counsel

Anders v. California, 386 U.S. 738 (sets procedure for counsel withdrawal when appeal is frivolous)
Penson v. Ohio, 488 U.S. 75 (requires appellate court to conduct independent review when counsel files Anders brief)
In re Schulman, 252 S.W.3d 403 (Tex. Crim. App.) (Texas standards for Anders briefs and procedures for appointed counsel withdrawal)
Kelly v. State, 436 S.W.3d 313 (Tex. Crim. App.) (clarifies procedural steps counsel must take in Anders context)
Bledsoe v. State, 178 S.W.3d 824 (Tex. Crim. App.) (addresses appellate court duties when reviewing Anders briefs)
Stafford v. State, 813 S.W.2d 503 (Tex. Crim. App.) (discusses requirements when counsel finds an appeal frivolous)
Ex parte Owens, 206 S.W.3d 670 (Tex. Crim. App.) (procedural guidance on post‑opinion notices and rights)