Unreported / Non-Citable
Background
Jonathon Andrew Salinas pleaded guilty in October 2024 to assault family violence and unlawful restraint, third-degree felonies enhanced by his habitual-felony-offender status. The trial court placed him on deferred adjudication community supervision for ten years. This appeal, docketed as No. 13-26-00464-CR, concerned those offenses in trial court cause No. 24-CRF-0445.
After Salinas admitted multiple alleged supervision violations in 2025, the trial court amended the conditions of his supervision and imposed sanctions. In 2026, the State again moved to revoke and adjudicate guilt. Salinas pleaded true to every allegation, and the trial court revoked his community supervision, adjudicated him guilty, and sentenced him to 25 years in prison, concurrent with the sentence imposed in a companion case.
The Court’s Holding
Salinas’s appointed appellate counsel filed an Anders brief and moved to withdraw, representing that a review of the record disclosed no arguable ground for appeal. The court concluded that counsel’s brief satisfied Anders and related Texas requirements, including providing record references, relevant authority, and notice to Salinas of his rights. Salinas neither sought timely access to the appellate record nor filed a pro se response.
After independently examining the entire record and counsel’s brief, the court found nothing that would arguably support an appeal. It therefore affirmed the trial court’s judgment and granted appointed counsel’s motion to withdraw.
Key Takeaways
- An appellate court receiving an Anders brief must independently examine the proceedings to determine whether the appeal is wholly frivolous.
- Salinas’s pleas of true supported revocation of his deferred adjudication community supervision and adjudication of guilt.
- The court found no arguable appellate issue and left the 25-year sentence intact.
Why It Matters
The memorandum opinion illustrates the procedure governing an Anders appeal in Texas, including counsel’s notice obligations and the appellate court’s duty to conduct its own review rather than relying solely on counsel’s assessment.
It also demonstrates the consequences of violating deferred-adjudication conditions when the charged felonies are enhanced by habitual-offender status: after revocation and adjudication, the defendant may face a substantial prison sentence.