Sidhom, Joseph Nabil, PD-1584-15

Indicted for theft; negotiated guilty plea and 8-year confinement with sentence suspended; appellant placed on 8-year community supervision.
State filed a motion to revoke probation, later amended; hearing held on amended motion.
Appellant pled true to some and not true to others at the January 14, 2015 revocation hearing.
Trial court revoked community supervision and imposed the previously suspended sentence.
Appellant timely noticed appeal; Court of Appeals affirmed in an unpublished opinion.
Petition for discretionary review contends the revocation hearing proceeded without valid intelligent, knowing, and voluntary waiver of the ten-day preparation period

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the district court erred in revoking probation after purported waiver	Sidhom argues waiver not intelligent/knowingly voluntary; insufficient private consultation	State contends waiver on the record satisfied art. 1.051(e) and was effective	No reversible error; waiver valid on record; court affirmed

Ashcraft v. State, 900 S.W.2d 817 (Tex. App. - Corpus Christi 1995) (addressing private consultation and waiver requirements)
Marin v. State, 851 S.W.2d 275 (Tex. Crim. App.1993) (waiver must be intelligent, knowing, voluntary)
Ponce v. State, 89 S.W.3d 110 (Tex. App. - Corpus Christi 2002) (waiver clarity and proper advisement requirements)
Rickels v. State, 202 S.W.3d 759 (Tex. Crim. App. 2006) (review of revocation decisions limited to abuse of discretion)
Saldano v. State, 70 S.W.3d 873 (Tex. Crim. App. 2002) (validates private consultation requirement for waiver)
Ex parte Carmona, 185 S.W.3d 492 (Tex. Crim. App. 2006) (timeliness and notice prerequisites for revocation proceedings)
Caddell v. State, 605 S.W.2d 275 (Tex. Crim. App. 1980) (timely known allegations prerequisite for revocation)