Joseph Darnell King v. the State of Texas
CourtTexas Court of Appeals, 7th District (Amarillo)
Date FiledJuly 27, 2026
Docket07-25-00236-CR
StatusPublished
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Full Opinion
In The
Court of Appeals
Seventh District of Texas at Amarillo
No. 07-25-00236-CR
JOSEPH DARNELL KING, APPELLANT
V.
THE STATE OF TEXAS, APPELLEE
On Appeal from the 320th District Court
Potter County, Texas
Trial Court No. 081787-D-CR, Honorable Steven Denny, Presiding
July 27, 2026
MEMORANDUM OPINION
Before DOSS and YARBROUGH and PRATT, JJ.
Appellant, Joseph Darnell King, appeals from the trial court’s judgment revoking
his community supervision for consuming alcohol in violation of the terms of his probation.
Following revocation of his deferred adjudication for possession of a controlled
substance,1 the trial court sentenced him to two years of confinement. His court-
1 See TEX. HEALTH & SAFETY CODE § 481.115(b).
appointed counsel has filed an Anders2 brief concluding that no arguable grounds for
reversal exist. After conducting an independent review of the record and considering
Appellant’s pro se response, we agree and affirm.
BACKGROUND
Appellant’s community supervision began on May 10, 2022, when he pleaded
guilty to possession of a controlled substance in an amount less than one gram. The trial
court placed him on deferred adjudication for three years. On April 20, 2023, the court
extended supervision for two additional years following offenses of public intoxication and
possession of drug paraphernalia. Among the conditions of his supervision, Appellant
was required to abstain from consuming alcohol in any form at any time.
On May 22, 2025, officers arrested Appellant for assault causing bodily injury to a
family member and alleged that he was under the influence of alcohol during the incident.
The State moved to proceed with adjudication, alleging Appellant violated his supervision
by both committing the assault and consuming alcohol. At the adjudication hearing, the
State waived the assault allegation and proceeded only on the alcohol-consumption
violation, to which Appellant pleaded “not true.”
The State presented testimony from two responding officers and Appellant’s
probation officer. Both officers testified that Appellant’s breath smelled of alcohol and
that his behavior was consistent with intoxication. Body-camera footage from one officer
captured the family-member victim stating that Appellant had been drinking Hennessy.
2 See Anders v. California, 386 U.S. 738, 87 S. Ct. 1396, 18 L. Ed. 2d 493 (1967). When appointed
appellate counsel, after a conscientious examination of the record, concludes that an appeal is frivolous,
counsel must file a brief identifying anything in the record that might arguably support the appeal. Id.
2
The probation officer recommended revocation, though the State acknowledged mid-trial
that a urinalysis conducted the day after arrest was negative for alcohol.
Appellant, his uncle, and his girlfriend testified in his defense. The uncle testified
that during the incident he inadvertently spilled beer on Appellant while attempting to
intervene. Appellant’s girlfriend testified that others at the residence were drinking, but
Appellant was not. Appellant testified that a missing tooth causes him to speak with what
sounds like a lisp or slurred speech and that he was taking medications that may have
made him appear intoxicated. The trial court found the alcohol-consumption violation
true, revoked probation, and imposed the original two-year sentence.
ANDERS FRAMEWORK
An Anders brief must present a professional evaluation of the record and explain
why the appeal presents no arguable grounds for reversal. See In re Schulman, 252
S.W.3d 403, 406–12 (Tex. Crim. App. 2008) (orig. proceeding). Counsel need not identify
specific arguable points where none exist, but the brief must include record references
and pertinent legal authorities. Id.; Davis v. State, 683 S.W.3d 828, 829–30 (Tex. App.—
Amarillo 2023, no pet.). Although his discussion of the potential issues on appeal is thin,
appellate counsel’s brief meets these requirements.
Counsel also certified that he notified Appellant of the Anders filing, provided
copies of the brief and motion to withdraw, informed Appellant of his right to file a pro se
response and to seek discretionary review, and delivered the appellate record. Appellant
filed a pro se response raising three complaints. We address each below.
3
Appellant’s pro se response raises claims of innocence, ineffective assistance of
counsel, and an alleged Brady violation.3 None presents an arguable ground for reversal.
The innocence claims reassert the defense the trial court rejected at the revocation
hearing. Because they identify no appellate error, they present nothing for our review.
See Bledsoe v. State, 178 S.W.3d 824, 827–28 (Tex. Crim. App. 2005).
The Brady claim rests on Appellant’s contention that the State did not disclose until
trial that his post-incident urinalysis was negative for alcohol. Whatever the merits of that
contention, the complaint was not preserved for our review. To preserve a Brady
complaint, a defendant must alert the trial court to the alleged violation through a timely
request for continuance, objection, or motion for new trial. Keeter v. State, 175 S.W.3d
756, 759–60 (Tex. Crim. App. 2005) (holding appellant cannot raise a Brady complaint
for the first time on appeal); Temple v. State, 342 S.W.3d 572, 591 (Tex. App.—Houston
[14th Dist.] 2010), aff’d on other grounds, 390 S.W.3d 341 (Tex. Crim. App. 2013) (finding
no preservation where appellant did not complain regarding the State’s untimely
disclosure as soon as grounds for an objection or complaint were apparent); Apolinar v.
State, 106 S.W.3d 407, 421 (Tex. App.—Houston [1st Dist.] 2003), aff’d on other grounds,
155 S.W.3d 184 (Tex. Crim. App. 2005) (“When evidence withheld in violation of Brady
is disclosed at trial, the defendant’s failure to request a continuance waives the error or
at least indicates that the delay in receiving the evidence was not truly prejudicial.”).
3 See Brady v. Maryland, 373 U.S. 83, 90, 83 S. Ct. 1194, 1198, 10 L. Ed. 2d 215 (1963).We note
that Texas prosecutors are also under an obligation, in certain circumstances, to produce evidence in the
“possession, custody, or control of the state or any person under contract with the state.” See State v.
Heath, 696 S.W.3d 677, 700 (Tex. Crim. App. 2024) (discussing TEX. CODE CRIM. PROC. § 39.14, et seq.).
4
The ineffective-assistance claim fails on this record. Appellant contends counsel
was ineffective for not timely objecting to the alleged Brady violation. Direct appeal is
ordinarily an inappropriate vehicle for such a claim because the record rarely contains an
explanation of counsel’s strategic decisions. See Rylander v. State, 101 S.W.3d 107,
110 (Tex. Crim. App. 2003) (holding that because the record on direct appeal typically
fails to discuss the reasonableness of counsel’s choices and facts that appear outside the
record, “an application for a writ of habeas corpus is the more appropriate vehicle to raise
ineffective assistance of counsel claims.”); Tones v. State, No. 03-04-00288-CR, 2005
Tex. App. LEXIS 2387, at *9 n.1 (Tex. App.—Austin Mar. 31, 2005, pet. ref’d, untimely
filed) (same holding in case involving allegations of ineffective assistance of counsel and
Brady violations). Nothing in the present appellate record would overcome the strong
presumption that counsel’s conduct fell within the wide range of reasonable professional
assistance. See Strickland v. Washington, 466 U.S. 668, 689 (1984).
We have carefully reviewed the record, counsel’s Anders brief, and Appellant’s pro
se response. Our independent review confirms appellate counsel’s assessment that the
appeal is wholly frivolous and without merit. Bledsoe v. State, 178 S.W.3d 824, 826 (Tex.
Crim. App. 2005). Proof of any single violation of the conditions of community supervision
is sufficient to support revocation. Shirley v. State, No. PD-0239-22, 2023 Tex. App.
Unpub. LEXIS 369, at *14 (Tex. Crim. App. Aug. 23, 2023).
5
Finding no arguable ground for appellate review, we grant counsel’s motion to
withdraw and affirm the trial court’s judgment.4
Lawrence M. Doss
Justice
Do not publish.
4 Counsel shall, within five days after this opinion is handed down, send Appellant a copy of the
opinion and judgment, along with notification of Appellant’s right to file a pro se petition for discretionary
review. See TEX. R. APP. P. 48.4. This duty is informational and ministerial in nature, does not involve legal
advice, and continues after this Court grants counsel’s motion to withdraw. In re Schulman, 252 S.W.3d at
411 n.33.
6