Elio Garza v. State, 13-15-00257-CR

Appellant Elio Garza was indicted for burglary of a habitation and placed on six years' deferred adjudication with a $1,000 fine.
The State filed a motion to adjudicate and revoke probation after alleged probation violations including a December 19, 2014 conviction for possession of marijuana, failure to report to probation officer for several months, curfew violation, and failure to perform community service.
At the adjudication hearing Garza pled "not true" to the motion; State presented probation officer testimony and fingerprint evidence linking Garza to the new offense.
Garza testified he was coerced, claimed threats by third parties (and alleged police involvement), said immigration officials lost his papers so he did not know where/when to report, and admitted pleading guilty to the marijuana charge because he felt he had to.
The trial court found the charged violations true, adjudicated Garza guilty of burglary of a habitation, and sentenced him to ten years' confinement.
Appointed counsel filed an Anders brief concluding no non-frivolous, reversible issues exist on appeal and requesting permission to withdraw while advising Garza of his right to file a pro se brief.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether any reversible error exists in the adjudication/revocation and sentence	State argued evidence (probation records, fingerprint match, new conviction, failure to report/community service/curfew violations) supports revocation and adjudication	Garza argued coercion, police misconduct, lost immigration papers prevented reporting, and inability to comply or pay while incarcerated	Trial court found violations true and adjudicated; appellate counsel concludes no reasonably arguable grounds for reversal (Anders brief)

Anders v. California, 386 U.S. 738 (U.S. 1967) (procedures for attorney withdrawal when appeal is frivolous)
Gagnon v. Scarpelli, 411 U.S. 778 (U.S. 1973) (due process requirements for probation revocation hearings)
In re Schulman, 252 S.W.3d 403 (Tex. Crim. App. 2008) (procedures for appellate counsel evaluating frivolous appeals)
Rickels v. State, 202 S.W.3d 759 (Tex. Crim. App. 2006) (standard of review for community supervision revocation)
Sanchez v. State, 603 S.W.2d 869 (Tex. Crim. App. 1980) (single violation can support revocation)
Jones v. State, 571 S.W.2d 191 (Tex. Crim. App. 1978) (appellant must successfully challenge all findings supporting revocation)
Williams v. State, 976 S.W.2d 871 (Tex. App.—Corpus Christi 1998) (appellate practice on Anders-type briefs)