Unreported / Non-Citable
Background
On December 12, 2023, Jesus Armando Flores pleaded guilty to driving while intoxicated, third or more offense, in the 242nd District Court of Hale County. The trial court suspended a five-year prison sentence and placed Flores on community supervision for five years subject to specific conditions.
On September 19, 2025, the State filed a Motion to Revoke Community Supervision, alleging two violations: testing positive for cocaine and failing to attend and complete the Hale County Drug Court program. At a hearing on December 22, 2025, Flores pleaded not true to the allegations, but the trial court found the violations proven, revoked supervision, and imposed a three-year prison sentence. Flores timely appealed.
The Court’s Holding
The appellate court affirmed the trial court’s judgment in full. Following Anders v. California procedures, appointed counsel moved to withdraw after concluding the appeal presented no non-frivolous grounds for reversal. Counsel’s brief examined all trial phases, adverse rulings, sufficiency of evidence, and assistance of counsel, identifying no errors warranting reversal.
The court independently reviewed the appellate record to identify any preserved issues that might support reversal and found none. After thorough examination, the panel agreed no plausible basis for reversal existed and accordingly: (1) affirmed the conviction and sentence, (2) affirmed the trial court’s judgment, and (3) granted counsel’s motion to withdraw.
Key Takeaways
- The conviction for third-or-more DWI stands with no reversible error in the trial proceedings or revocation hearing.
- Trial courts properly revoke community supervision when conditions are violated, including positive drug tests and failure to complete required programming.
- The appellate court’s independent review under Anders procedures confirmed no appellable issues existed despite opportunity for counsel to contest the conviction.
- The three-year prison sentence imposed after revocation of supervision was upheld on appeal.
Why It Matters
This decision illustrates the serious consequences of violating community supervision conditions, particularly in DWI cases. Trial courts retain broad discretion in supervising defendants released from incarceration, and breach of conditions—especially substance-related violations in DUI contexts—commonly results in imposition of prison time.
The case also demonstrates appellate courts’ rigorous application of Anders review standards. Even when appointed counsel cannot identify non-frivolous grounds for appeal, courts conduct independent examination of the record to ensure no reversible error was overlooked. Here, that scrutiny found none, affirming both the trial court’s management of the conviction and the revocation proceeding.