Background
Shadavia Nykeitha Motton pleaded guilty to continuous violence against a person with whom she had a dating relationship, a third-degree felony. Under a negotiated plea agreement, the trial court placed her on deferred adjudication community supervision for six years rather than imposing immediate imprisonment. Subsequently, the State filed a motion to adjudicate her guilt and revoke community supervision, alleging multiple violations of the conditions.
At a contested hearing on the State’s motion, Motton pleaded “not true” to all but one alleged violation. The trial court found the violations proven, adjudicated her guilty, revoked her community supervision, and imposed a sentence of four years in prison in the Texas Department of Criminal Justice Institutional Division.
Motton appealed. Her court-appointed counsel filed an Anders motion to withdraw, concluding after professional examination of the record that no arguable grounds for appeal existed. Motton did not file a pro se response to counsel’s brief.
The Court’s Holding
The Eleventh Court of Appeals granted counsel’s motion to withdraw and affirmed the trial court’s judgment. Following Anders procedures, the appellate court independently reviewed the record and likewise found the appeal to be without merit.
The court held that proof of a single violation of a probationer’s community supervision conditions is legally sufficient to support revocation. Critically, because Motton had pleaded “true” to one violation—which the trial court accepted—that admission alone was sufficient to sustain the revocation order. The court emphasized that a plea of “true” standing alone is sufficient evidence to support revocation; no additional proof of the other alleged violations was necessary.
Key Takeaways
- One proven violation of community supervision conditions is legally sufficient to support revocation of deferred adjudication.
- A defendant’s plea of “true” to a violation constitutes sufficient evidence for revocation and requires no additional corroborating proof.
- The court applied settled Texas precedent holding that admissions by defendants at violation hearings independently support revocation decisions.
Why It Matters
This decision underscores the significant risk defendants face on deferred adjudication and community supervision. While deferred adjudication offers an opportunity to avoid formal conviction and incarceration, the price of even a single violation can be catastrophic—revocation results in adjudication of guilt and imposition of the original sentence. The holding makes clear that admissions at violation hearings are particularly damaging, as they provide the trial court with all the proof needed to revoke.
For practitioners, the decision reinforces that a defendant who pleads “true” to even one violation at a revocation hearing should expect revocation; the presence of multiple alleged violations becomes largely irrelevant once one is admitted. This has strategic implications for clients negotiating or contesting violation allegations.