Unreported / Non-Citable
Background
Hubert Saddler filed notices of appeal on August 12, 2026, following a hearing at which the trial court apparently revoked his community supervision, adjudicated him guilty, and imposed sentence. Although the district clerk’s certificates of proceedings summarized the trial court’s rulings, the appellate court received no signed trial-court orders memorializing them.
The next day, the trial court signed orders granting a new hearing on the probation revocation. The appellate record contained no later orders. The court of appeals notified Saddler that it appeared to lack jurisdiction and warned that it would dismiss the appeals unless a party supplied a signed, appealable order in each case within ten days. No party responded.
The Court’s Holding
The Texas Second Court of Appeals dismissed both appeals for lack of jurisdiction. Because the trial court had granted a new revocation hearing and the record contained no subsequent signed orders resolving the matters, there were no signed, appealable orders for the appellate court to review.
The court also treated the district clerk’s certificates of proceedings as insufficient to establish appellate jurisdiction. Those certificates summarized what occurred at the hearing but did not constitute appealable trial-court orders.
Key Takeaways
- A criminal appeal requires a signed, appealable trial-court order.
- A district clerk’s certificate summarizing oral rulings does not substitute for an appealable order.
- When the appellate record contains no appealable order and the parties do not cure the deficiency after notice, dismissal for lack of jurisdiction is appropriate.
Why It Matters
The decision underscores the need to confirm that the record contains a signed order before pursuing a criminal appeal. An oral ruling or clerk-prepared account of a hearing will not supply appellate jurisdiction when no appealable order has been signed.