Ex Parte Justin Michael Love, 02-21-00017-CR

Justin Michael Love is charged with engaging in organized criminal activity (drug dealing) with murder as the predicate offense; a prior conviction and 50-year sentence were reversed on appeal.
After reversal the trial court set bail at $500,000 and imposed restrictive bond conditions: home confinement (6:00 p.m.–8:00 a.m.), limited permitted travel, no contact with witnesses except his estranged wife (Tamilyn); GPS monitoring was later added.
The State moved to revoke bond, alleging Love violated curfew/home-confinement and travel limits (visits to girlfriend, Tamilyn’s home and workplace, park, restaurant), failed to maintain suitable employment, visited a listed witness’s home, and repeatedly harassed Tamilyn (multiple calls/texts, threats including to cut off his ankle monitor).
At the revocation hearing the trial court found Love violated the bond terms (including committing a new offense under the harassment statute) and that the violated conditions related to community safety; it revoked bond and denied bail pending retrial.
Love sought habeas relief; on appeal he argued (1) the State failed to show his violations endangered community safety and (2) his harassment could not be a new offense in light of Ex parte Barton. The Court of Appeals affirmed based on the first issue.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court erred in finding Love's bond-condition violations related to community safety	Love: State failed to prove the violations endangered the community; revocation requires proof of endangerment	State: Home confinement and electronic monitoring are bond conditions that relate to community safety; violating them supports revocation	Held: Affirmed. Section 11b requires that the violated condition relate to safety, not that the violation actually caused immediate harm; trial court did not abuse discretion
Whether Love’s harassment of his estranged wife could constitute a new criminal offense given Ex parte Barton	Love: Court previously found part of the harassment statute unconstitutional, so his conduct cannot be a new offense	State: Trial court found harassment violated the statute and constituted a new offense supporting revocation	Held: Court did not reach this issue—moot because revocation was upheld on the public-safety ground

Love v. State, 600 S.W.3d 460 (Tex. App. — Fort Worth 2020) (prior reversal of Love’s conviction for structural error)
Ex parte Barton, 586 S.W.3d 573 (Tex. App. — Fort Worth 2019) (addressing constitutionality of part of the harassment statute)
Johnson v. Tenth Judicial Dist. Court of Appeals at Waco, 280 S.W.3d 866 (Tex. Crim. App. 2008) (interpretation of constitutional provisions by plain meaning)
Ex parte Wheeler, 203 S.W.3d 317 (Tex. Crim. App. 2006) (standard of review for pretrial habeas rulings)
Ex parte Martin, 6 S.W.3d 524 (Tex. Crim. App. 1999) (de novo review when facts undisputed and pure law involved)
Ex parte McIntyre, 558 S.W.3d 295 (Tex. App. — Fort Worth 2018) (upholding trial court if correct under any theory)
Ex parte Rubac, 611 S.W.2d 848 (Tex. Crim. App. 1981) (accused bears burden to show trial court abused discretion in setting bail)
Ex parte Shires, 508 S.W.3d 856 (Tex. App. — Fort Worth 2016) (discussing Section 11b and community-safety considerations for bond revocation)
Ex parte Allen-Pieroni, 524 S.W.3d 252 (Tex. App. — Waco 2016) (discussing GPS monitoring and bond-setting discretion)
Ex parte Anunobi, 278 S.W.3d 425 (Tex. App. — San Antonio 2008) (upholding home confinement to protect victims and community)
Smith v. State, 993 S.W.2d 408 (Tex. App. — Houston [14th Dist.] 1999) (forfeiture of challenges not raised when condition was imposed)