Unreported / Non-Citable
Background
Adrian Lujan pleaded guilty in April 2025 to second-degree felony aggravated assault with a deadly weapon. Under a plea agreement, the trial court deferred adjudication and placed him on community supervision for ten years.
The State later petitioned to adjudicate Lujan’s guilt, alleging multiple supervision violations. After the State waived several allegations and amended another, Lujan pleaded true to failing to pay supervision fees and failing to complete community service, while contesting allegations that he unlawfully carried a weapon and possessed a firearm. Evidence from an inventory search of his vehicle included two firearms, suspected narcotics, digital scales, and $7,824 in cash. The trial court found the four remaining allegations true, adjudicated Lujan guilty, revoked his supervision, and sentenced him to 17 years in prison.
The Court’s Holding
Lujan’s appointed appellate counsel filed an Anders brief and moved to withdraw, concluding after reviewing the record that the appeal presented no arguable grounds for reversal. Lujan received the record and notice of his right to respond but filed no pro se response.
After independently reviewing the entire record, the Seventh Court of Appeals agreed that the appeal was wholly frivolous and without merit. Because proof of a single supervision violation was sufficient to support adjudication, Lujan’s pleas of true to the unpaid-fees and incomplete-community-service allegations independently supported the trial court’s decision. The appellate court affirmed the judgment and granted counsel’s motion to withdraw.
Key Takeaways
- A single proven violation of a community-supervision condition can support adjudication of guilt.
- Lujan’s pleas of true to two violations were sufficient even without relying on the contested firearm-related allegations.
- The appellate court’s independent Anders review found no plausible basis to reverse the conviction or sentence.
Why It Matters
The decision illustrates the significant effect of pleading true to an alleged community-supervision violation: one such admission may independently sustain adjudication and revocation. It also reflects an appellate court’s duty in an Anders proceeding to examine the complete record rather than merely accept counsel’s assessment that an appeal is frivolous.