Ex Parte Shawn Michael Donaldson, 14-16-00092-CR

Appellant Shawn Michael Donaldson was on five years’ deferred adjudication probation for two prior felonies (aggregate felony criminal mischief and enticing a child) when indicted for sexual assault of a child alleged to have occurred while he was on probation.
The State moved to adjudicate guilt on the prior offenses after the new indictment.
The trial court set bail at $250,000 for the sexual-assault indictment and $10,000 each for the two prior felony matters (total $270,000).
Donaldson filed a pretrial habeas application claiming bail was excessive; at the hearing his mother testified she could afford $24,000 and that the father would arrange employment and assure appearance; no other evidence was introduced.
The trial court denied relief; Donaldson appealed, arguing the total bail violated Texas law and the Eighth Amendment.
The court of appeals affirmed, finding the trial court did not abuse its discretion given the seriousness of the charged offense, potential punishment, alleged commission while on probation, scant evidence on inability to pay, and community-safety considerations.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether $270,000 bail is excessive under Tex. Code Crim. Proc. art. 17.15 and constitutional protections	Bail is excessive and violates state and federal constitutional protections; mother testified family could afford $24,000	Bail is reasonable based on offense severity, potential sentence, alleged probation violation, and limited proof of inability to pay	Affirmed: bail not excessive; trial court did not abuse discretion

Ex parte Rubac, 611 S.W.2d 848 (Tex. Crim. App. 1981) (standard: abuse-of-discretion review and factors for bail determination)
Ex parte Kimes, 872 S.W.2d 700 (Tex. Crim. App. 1993) (applicant bears burden to present record showing entitlement to relief)
Ex parte Gentry, 615 S.W.2d 228 (Tex. Crim. App. 1981) (reducing bail only when applicant satisfies burden)
Ex parte Castillo–Lorente, 420 S.W.3d 884 (Tex. App.—Houston [14th Dist.] 2014) (appellate deference where reasonable disagreement exists)
Ex parte Tata, 358 S.W.3d 392 (Tex. App.—Houston [1st Dist.] 2011) (bail must assure appearance and not be used to oppress)
Milner v. State, 263 S.W.3d 146 (Tex. App.—Houston [1st Dist.] 2006) (applicant carries burden to show excessiveness of bail)
Clemons v. State, 220 S.W.3d 176 (Tex. App.—Eastland 2007) (comparison of bail amounts in serious child-sex offense cases)
Ex parte Scott, 122 S.W.3d 866 (Tex. App.—Fort Worth 2003) (ability to make bail is one factor; lack of evidence on resources supports denial)
Ex parte Ruiz, 129 S.W.3d 751 (Tex. App.—Houston [1st Dist.] 2004) (documentary proof required to show inability to make bail)
Ex parte Chavfull, 945 S.W.2d 183 (Tex. App.—San Antonio 1997) (future safety of victim/community may justify denying bond reduction)
Ex parte Melartin, 464 S.W.3d 789 (Tex. App.—Houston [14th Dist.] 2015) (district court bail schedules may be considered but are not binding)