Lionso Cisneros, Jr. v. the State of Texas, 07-20-00352-CR

Appellant Lionso Cisneros, Jr. was charged with forgery of a financial instrument (state jail felony).
In Sept. 2016 Cisneros pled guilty and received a 12‑month state‑jail sentence, $1,000 fine, costs, fees, and restitution; the sentence was suspended and he was placed on four years’ community supervision.
The State moved to revoke supervision; at the revocation hearing Cisneros pleaded “true” to the State’s allegations except as to community service hours.
The trial court found multiple supervision violations and sentenced Cisneros to the previously suspended term.
Appellate counsel filed a motion to withdraw supported by an Anders brief, certifying a conscientious review and concluding the appeal is frivolous; appellant received notice and did not file a pro se response.
The court of appeals conducted an independent review, found no nonfrivolous appellate issues, granted counsel’s motion to withdraw, and affirmed the trial court’s judgment.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Validity of community‑supervision revocation	Cisneros disputed some allegations (notably community‑service hours)	Most allegations admitted as true; admissions and record support revocation	Revocation findings upheld; sentence imposed per suspended sentence
Effect of plea of “true” on appellate review	A plea of “true” might leave room to challenge some claims	Plea admits violations and limits preserved appellate issues	Plea forecloses challenges to admitted violations; no reversible error found
Adequacy of appointed counsel’s Anders motion/brief	Counsel must meet procedural requirements; appellant could argue noncompliance	Counsel certified review and complied with Texas and federal Anders procedures	Court found counsel complied with controlling authorities and permitted withdrawal
Duty of appellate court to independently review record	Appellant could claim insufficient appellate review	Appellate court required to search for nonfrivolous issues under precedent	Court performed independent review, found no nonfrivolous issue, affirmed

Anders v. California, 386 U.S. 738 (establishes procedure for appointed counsel to withdraw when appeal is frivolous)
In re Schulman, 252 S.W.3d 403 (Texas standards for Anders motions and counsel’s duties)
Kelly v. State, 436 S.W.3d 313 (clarifies appointed counsel’s obligations when filing Anders brief)
Penson v. Ohio, 488 U.S. 75 (requires appellate courts to independently review the record for nonfrivolous issues)
High v. State, 573 S.W.2d 807 (prior Texas authority on counsel’s obligations when seeking withdrawal)
Gainous v. State, 436 S.W.2d 137 (precedent on frivolous appeals and appellate review)