Holloway, Jonathan Demont v. State, 05-11-01602-CR

Holloway pleaded guilty to aggravated robbery in 2006, received deferred adjudication, four years’ community supervision, and a $1,000 fine.
In 2009, the State moved to adjudicate guilt in the aggravated robbery case for supervision violations, and the court continued supervision with new conditions (60 days in jail, treatment, random urinalysis).
In 2009, the State filed a second motion to adjudicate guilt in the assault involving family violence (and unpaid fees), Holloway pleaded guilty to the assault in 2010, with deferred adjudication and a four-year supervision term, plus a $500 fine, and the aggravated robbery supervision was extended by two years.
On December 28, 2010, the State moved to adjudicate guilt in both cases, alleging THC positives and failure to report to his probation officer.
The October 11, 2011 hearing proceeded; Holloway admitted true to THC positives and failure to report after acknowledging rights and waiving them, and indicated he would abide by conditions if continued on supervision.
The trial court granted the motions, adjudicated Holloway guilty on both offenses, and sentenced six years’ imprisonment on each offense.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Preservation of due process claim	Holloway argues lack of timely notice violated due process	State contends preservation requirements were not met for appellate review	Claim not preserved; affirmed

Pena v. State, 285 S.W.3d 459 (Tex. Crim. App. 2009) (preservation requires timely, specific objections)
Lankston v. State, 827 S.W.2d 907 (Tex. Crim. App. 1992) (clear, specific request needed for review)
Fuller v. State, 253 S.W.3d 220 (Tex. Crim. App. 2008) (almost all error may be forfeited without objection)
Curry v. State, 910 S.W.2d 490 (Tex. Crim. App. 1995) (objection and adverse ruling required to preserve error)
Wilson v. State, 311 S.W.3d 452 (Tex. Crim. App. 2010) (per curiam; preserved error standard reiterated)