John L. McLaughlin, Jr. v. State
07-16-00079-CR
| Tex. App. | Oct 27, 2016Background
- John L. McLaughlin Jr. pled guilty to aggravated robbery and received 10 years’ deferred adjudication under a plea agreement.
- The State filed a motion to adjudicate (probation revocation); at the first adjudication hearing the court adjudicated guilt and sentenced life, but later granted a new trial.
- At the second adjudication hearing McLaughlin pled “True” to the State’s motion and the court heard punishment evidence.
- The trial court sentenced McLaughlin to 30 years in the Texas Department of Criminal Justice.
- McLaughlin appealed, arguing his plea of “True” was involuntary because the court failed to give the Article 26.13 admonishments (range of punishment, consequences of pleading true, mental-health, immigration, voluntariness).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Article 26.13 admonishments are required before accepting a plea of “True” in a motion to adjudicate | McLaughlin: Article 26.13 requires admonishments (range, consequences, mental health, immigration, voluntariness) before plea | State/Court: Article 26.13 applies only to pleas of guilty or nolo contendere in felony prosecutions, not to revocation/adjudication pleas like “True” | Court held Article 26.13 does not apply to pleas of “True” in adjudication proceedings; no abuse of discretion |
| Whether due process required Article 26.13 admonishments or other procedural protections beyond Gagnon | McLaughlin: Due process requires substantial compliance with procedural rules (citing Leonard) | State/Court: Due process in revocation is governed by Gagnon protections; those were provided here | Court held due process requirements were satisfied (notice, disclosure, hearing, confrontation, neutral judge, written findings); plea was voluntary |
Key Cases Cited
- Leonard v. State, 385 S.W.3d 570 (Tex. Crim. App. 2012) (standard of review for revocation proceedings and due-process context)
- Gutierrez v. State, 108 S.W.3d 304 (Tex. Crim. App. 2003) (Article 26.13 applies only to pleas of guilty or nolo contendere in felony prosecutions; not to probation revocation)
- Gagnon v. Scarpelli, 411 U.S. 778 (U.S. 1973) (due-process protections required in probation revocation proceedings)
- Caddell v. State, 605 S.W.2d 275 (Tex. Crim. App. 1980) (applies Gagnon due-process framework to Texas revocation proceedings)
Outcome: Affirmed—trial court did not abuse its discretion; plea of “True” was voluntary and due process was afforded.