Stephanie Mechelle Coleman v. State, 11-16-00118-CR

Appellant Stephanie Mechelle Coleman pleaded guilty to theft by check (under $1,500 with two priors) in three causes; trial court imposed convictions, $500 fine, and five-year community supervision in each cause.
The State later moved to revoke Coleman’s community supervision in all three causes.
At the revocation hearing Coleman pleaded true to the State’s allegations; the trial court found the allegations true and revoked supervision in each cause.
The court sentenced Coleman to two years’ confinement in a state jail facility on each cause and imposed the original $500 fines.
Court-appointed appellate counsel filed Anders-style motions to withdraw, concluding the appeals were frivolous and provided Coleman with records and notice; Coleman filed a pro se response.
The court conducted an independent review under Anders/Schulman and concluded no reversible error existed, granted counsel’s motions to withdraw, and dismissed the appeals.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether revocation was invalid despite plea of true	Coleman argued (pro se) that matters from original plea could affect revocation	State argued a true plea is sufficient to support revocation	Revocation affirmed: a plea of true alone supports revocation (no reversible error)
Whether appellate counsel properly moved to withdraw	Coleman contended counsel should continue or raise issues	Counsel argued they complied with Anders/related Texas authorities and appeals are frivolous	Withdrawal granted: counsel complied with required procedures
Whether issues from original plea can be raised on revocation appeal	Coleman sought to challenge original plea proceedings	State argued issues from original plea generally cannot be raised on revocation appeal absent a void judgment	Held for State: such issues are not reviewable on revocation appeal unless judgment is void
Whether the appeals were frivolous such that dismissal was proper	Coleman argued there were arguable grounds for appeal	Counsel and the court concluded no arguable, non-frivolous issues existed after independent review	Court dismissed the appeals as frivolous and without merit

Anders v. California, 386 U.S. 738 (1967) (requires counsel to file brief stating case is frivolous and to provide the client with record and notice before withdrawing)
In re Schulman, 252 S.W.3d 403 (Tex. Crim. App. 2008) (procedure for court review of Anders briefs and pro se responses in Texas)
Kelly v. State, 436 S.W.3d 313 (Tex. Crim. App. 2014) (addressing appellate counsel’s duties in Anders-type withdrawals)
Bledsoe v. State, 178 S.W.3d 824 (Tex. Crim. App. 2005) (standards for reviewing Anders briefs and pro se responses)
Moses v. State, 590 S.W.2d 469 (Tex. Crim. App. 1979) (a plea of true is sufficient to support revocation of community supervision)
Jordan v. State, 54 S.W.3d 783 (Tex. Crim. App. 2001) (issues from original plea generally cannot be raised on revocation appeal)
Traylor v. State, 561 S.W.2d 492 (Tex. Crim. App. 1978) (same principle limiting review of prior plea in revocation appeals)