Shahid Karriem Ansari, III v. State, 06-14-00220-CR

Background

Ansari was on deferred-adjudication community supervision for burglary of a habitation; the State filed a motion to revoke alleging six violations (including resisting arrest, possession of marijuana, unpaid fees, missed community service, and failure to complete anger-management).
At the adjudication hearing Ansari pled true to resisting arrest, possession of marijuana, and failure to complete anger-management; the State abandoned some fee/community-service grounds after the plea.
The trial court revoked supervision, adjudicated Ansari guilty of burglary, and sentenced him to seven years’ incarceration.
On appeal Ansari claimed ineffective assistance of trial counsel for failing to develop mitigating evidence, limited cross-examination, and inadequate investigation after counsel’s late appointment.
He also argued the anger-management requirement was unconstitutionally vague because the order lacked a completion deadline; he did not raise this issue when supervision was imposed.
The appellate court found the record undeveloped on counsel’s strategy, Ansari failed to show what additional evidence or investigation would have produced, his guilty pleas supported revocation, and the vagueness challenge was waived for failure to timely appeal.

Issues

Issue	Plaintiff's Argument (Ansari)	Defendant's Argument (State)	Held
Whether trial counsel provided ineffective assistance at adjudication/sentencing	Counsel failed to elicit mitigating evidence, inadequately cross-examined the State's witness, and had insufficient time to investigate new allegations	The record does not show what mitigation or investigative leads existed; counsel’s actions may reflect reasonable strategy; guilty pleas undermine prejudice	Court held Ansari failed to show deficient performance or prejudice under Strickland; claim denied
Whether counsel’s limited investigation after late appointment was constitutionally deficient	Late appointment made meaningful investigation impossible, constituting ineffective assistance	Plea of true to allegations reduces need for full independent factual investigation; no showing of what investigation would have revealed	Court held absence of record proof of prejudice or deficiency; claim fails
Whether the anger-management condition was unconstitutionally vague	Condition lacked a deadline so it was ambiguous and not a proper basis for revocation	Vagueness claim must be raised on direct appeal when condition is imposed; Ansari waived the issue	Court held claim waived for failure to timely challenge condition
Whether pleas of true preclude Strickland prejudice showing	N/A	Pleas of true to violations are sufficient to support revocation and preclude a showing of prejudice from counsel’s alleged failings	Court held pleas of true to multiple grounds supported revocation and foreclosed prejudice prong

Key Cases Cited

Strickland v. Washington, 466 U.S. 668 (ineffective assistance requires deficient performance and prejudice)
Thompson v. State, 9 S.W.3d 808 (direct-appeal record often inadequate for ineffective-assistance claims)
Lopez v. State, 343 S.W.3d 137 (ineffectiveness must be apparent from the record to resolve on direct appeal)
Eddie v. State, 100 S.W.3d 437 (plea of true reduces need for full independent factual investigation in revocation)
McDonald v. State, 608 S.W.2d 192 (plea of true alone is sufficient to support revocation)
Garcia v. State, 57 S.W.3d 436 (presumption that counsel’s choices reflect reasonable trial strategy)