A Texas appellate court has upheld the revocation of Michael Richard Waleski's community supervision after he violated several terms set by the court. This decision affects Waleski, who was previously convicted of felonies related to family violence and protective order violations. The ruling emphasizes the importance of adhering to court-ordered conditions during probation.
The Texas Court of Appeals, 11th District, issued its opinion on July 23, 2026, in case number 11-25-00097-CR. Waleski had originally pled guilty to two felony charges: continuous violence against the family and violating a protective order. As part of a plea agreement, he was sentenced to ten years in confinement, which was suspended in favor of ten years of community supervision.
The dispute arose when the State of Texas moved to revoke Waleski's community supervision after he allegedly failed to comply with its terms. The State claimed that Waleski had consumed alcohol, entered establishments where alcohol is sold, and committed assault. At a hearing, he admitted to drinking alcohol but denied the other allegations. The trial court found sufficient evidence to revoke his community supervision based on his admission and testimony from his probation officer.
The court ruled that the State only needed to prove a violation of community supervision terms by a preponderance of the evidence. The opinion noted, "the evidence presented at the hearing, although contested, is sufficient to support the trial court’s findings of 'true' of allegation one in each cause." The judges on the panel included Chief Justice Bailey, Justice Trotter, and Justice W. Bruce Williams.
The court's decision underscores the legal principle that only one violation of community supervision terms is enough for revocation. The ruling stated, "It is well-settled that proof of only a single violation of the terms and conditions of a probationer’s community supervision is sufficient to support the trial court’s revocation order." This means that even if Waleski had successfully contested some allegations, the admission of alcohol consumption alone was enough to uphold the revocation.
Going forward, this ruling serves as a reminder of the strict adherence required for individuals on community supervision. It highlights the consequences of violating the terms set forth by the court, particularly regarding substance use. Such decisions can have lasting impacts on individuals' lives, especially for those with prior convictions.
Waleski's case is significant as it illustrates how the courts handle violations of community supervision. The ruling does not appear to set new legal precedent but reinforces existing standards regarding the revocation of community supervision in Texas. Individuals on probation should be aware that violations can lead to serious repercussions.
As for what’s next, Waleski has the option to file a petition for discretionary review, which could potentially bring the case before a higher court. However, details regarding any related cases or further appeals were not available in the court filing.