Juan Leal, Jr. v. State, 03-15-00095-CR

Leal pleaded guilty to felony assault family violence and received deferred-adjudication community supervision for three years.
The State filed a second amended motion to proceed with adjudication, alleging 23 violations of the supervision terms, including drug offenses and additional family-violence acts.
During a hearing the district court found the allegations true, stated some reasons orally, adjudicated Leal guilty, and sentenced him to 18 years’ imprisonment.
Leal appealed asserting the judgment should delete two violations not mentioned orally; he claimed the oral pronouncement should control.
The court held there is no conflict between oral pronouncement and written judgment; written order revoking supervision controls, and the district court’s findings at the hearing do not negate the written findings.
The judgment adjudicating guilt is affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does the written judgment conflict with the oral pronouncement?	Leal argues the oral pronouncement controls.	State argues no conflict; written judgment governs.	No conflict; written judgment controls.

Sanchez v. State, 603 S.W.2d 869 (Tex. Crim. App. 1980) (any one finding can support revocation)
Joseph v. State, 3 S.W.3d 627 (Tex. App.—Houston [14th Dist.] 1999) (evidence sufficiency for revocation)
Coffey v. State, 979 S.W.2d 326 (Tex. Crim. App. 1998) (standard for written vs. oral findings)
Clapper v. State, 562 S.W.2d 250 (Tex. Crim. App. 1978) (revocation procedures and findings)
Ablon v. State, 537 S.W.2d 267 (Tex. Crim. App. 1976) (prior revocation principles)
Balli v. State, 530 S.W.2d 123 (Tex. Crim. App. 1975) (procedural standards for revocation)
Taylor v. State, 131 S.W.3d 497 (Tex. Crim. App. 2004) (oral vs. written sentence controls when applicable)