Background

• Garza was adjudicated guilty of aggravated assault with a deadly weapon and sentenced to 10 years in TDCJ after a motion to adjudicate probation was granted.
• He had previously entered six years of deferred adjudication for the same offense.
• A State motion to adjudicate guilt alleging multiple probation violations was filed January 20, 2015 and the trial court found those violations true.
• Probation testimony included a probation officer detailing violations (failure to report, new arrest, curfew, no community service, etc.) and fingerprint evidence tying Garza to the prior offense.
• Garza testified in his own defense, alleging coercion and various misconduct by law enforcement, and explained language barriers and immigration issues affecting compliance.
• Counsel filed an Anders brief seeking permission to withdraw, asserting no reversible error and limited to due-process review under applicable case law.

Issues

Key Cases Cited

• In re Schulman, 252 S.W.3d 403 (Tex.Crim.App. 2008) (framework for Anders briefs and record reference)
• Hawkins v. State, 112 S.W.3d 340 (Tex.App.–Corpus Christi 2003, no pet.) (due process and revocation standards)
• Gagnon v. Scarpelli, 411 U.S. 778 (1973) (minimum due-process requirements in probation revocation)
• Rickels v. State, 202 S.W.3d 759 (Tex. Crim. App. 2006) (standard for reviewing probation-revocation decisions)
• 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) (requirement to challenge all findings supporting revocation)
• Williams v. State, 976 S.W.2d 871 (Tex. App.—Corpus Christi 1998) (Anders briefing and preservation procedures)