The Texas Court of Appeals has upheld the conviction of Leonardo Julian for violating a family-violence protective order. This decision, issued on October 16, 2026, affects individuals involved in domestic violence cases and highlights the importance of adhering to protective orders.

Julian was found guilty of violating a protective order obtained by his former partner, Jennifer Calixto. The court's ruling emphasizes the legal obligations imposed by such orders and the consequences of ignoring them.

BACKGROUND

Leonardo Julian and Jennifer Calixto had a long-term romantic relationship that ended when Calixto sought a family-violence protective order against Julian. This order prohibited him from approaching her residence, specified as 9595 Westview Drive #703. Two months later, Calixto filed a notification of change of address with the court, stating her new residence at 1605 Huge Oaks Street and indicating that she did not want her new address to remain confidential.

Three months after the address change, Julian appeared at Calixto's new residence late at night. Calixto heard loud music and saw Julian parked nearby. Alarmed, she called 9-1-1, leading to Julian's arrest. The State charged him with violating the protective order, and Calixto was the sole witness during the trial, which resulted in Julian's conviction.

THE RULING

The court ruled that the evidence presented was sufficient to support the jury's verdict. Julian argued that he was unaware of Calixto's new address and that the State failed to prove he received notice of the change. However, the court found that the State did not need to prove delivery of the change-of-address notification as an element of the offense. The court stated, "While the introduction of evidence of delivery is one way in which the State could have proved that Julian knew Calixto resided at 1605 Huge Oaks Street, the State was not restricted to this method of proving he knew she lived there."

Additionally, the court noted that circumstantial evidence suggested Julian was aware of Calixto's residence. The court pointed out that Julian had previously lived at the address and had a connection to the elderly couple who owned the home. The court concluded that a rational juror could infer that Julian knowingly violated the protective order by visiting Calixto's residence.

IMPACT

This ruling reinforces the legal significance of family-violence protective orders in Texas. It serves as a reminder that individuals who are subject to such orders must comply with their terms, regardless of whether they have received formal notification of any changes in the protected person's address. The decision also illustrates how circumstantial evidence can play a crucial role in establishing a violation of protective orders.

Going forward, this ruling may influence how courts interpret the requirements for proving knowledge of a protective order and its terms. It emphasizes the importance of ensuring that protective orders are followed and that violations are taken seriously, particularly in cases involving family violence.

WHAT'S NEXT

Julian has the option to appeal the ruling, although details were not available in the court filing regarding any potential appeal. This case may also lead to further discussions about the adequacy of jury instructions in similar cases and the standards for proving knowledge of protective orders.