Jennifer R. Fulton v. the State of Texas

CourtTexas Court of Appeals, 7th District (Amarillo)
DecidedMay 11, 2026
Docket07-26-00035-CR
StatusPublished

This text of Jennifer R. Fulton v. the State of Texas (Jennifer R. Fulton v. the State of Texas) is published on Counsel Stack Legal Research, covering Texas Court of Appeals, 7th District (Amarillo) primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Jennifer R. Fulton v. the State of Texas, (Tex. Ct. App. 2026).

Opinion

In The Court of Appeals Seventh District of Texas at Amarillo

No. 07-26-00035-CR

JENNIFER R. FULTON, APPELLANT

V.

THE STATE OF TEXAS, APPELLEE

On Appeal from the Criminal District Court 4 Tarrant County, Texas1 Trial Court No. 1855457, Honorable Andy Porter, Presiding

May 11, 2026 MEMORANDUM OPINION Before DOSS and YARBROUGH and PRATT, JJ.

Appellant, Jennifer R. Fulton, appeals from the trial court’s order revoking her

community supervision, adjudicating her guilty of the offense of assault with bodily injury

on a family or household member with a previous conviction, and sentencing her to serve

ten years of imprisonment. By four issues, Appellant contends the trial court erred and

deprived her of her due process rights by including a fine and certain fees in the judgment.

We affirm the judgment as modified herein.

1 Because this matter was transferred from the Second Court of Appeals, we apply its precedent

when it conflicts with that of the Seventh Court of Appeals. TEX. R. APP. P. 41.3. BACKGROUND

Appellant was charged with the third-degree felony offense of assault causing

bodily injury to a family member with a previous conviction for same. She pleaded guilty

to the offense in June 2025, and the court placed her on deferred adjudication community

supervision for two years. Her community supervision was subject to certain terms and

conditions.

Two weeks later, the State filed a motion to proceed to adjudication, alleging

Appellant violated the terms and conditions of her community supervision by committing

the offense of driving while intoxicated on July 1, 2025, and consuming alcohol on July 1,

2025. The court held a hearing on the motion in November 2025. The State waived the

first allegation and proceeded on the second. The State presented evidence supporting

its second allegation. During her testimony, Appellant admitted to violating the condition

of her community supervision that prohibited her from drinking. At the conclusion of the

hearing, the trial court found the allegation to be true and assessed punishment against

Appellant at ten years of imprisonment and noted she had a “balance of $787.50 in

restitution owing to Tarrant County Texas” and imposed it as part of the judgment. It did

not orally pronounce a fine.

The written judgment includes a fine of $500.00. It also includes a “special finding”

setting forth reparations in the amount of $443.00. The Bill of Costs includes $787.50 in

attorney’s fees and a $15.00 time-payment fee.

2 ANALYSIS

By four issues, Appellant argues (1) the trial court deprived her of due process of

law in ordering her to repay $787.50 in appointed attorney’s fees because there is no

evidence to support a finding that she was no longer indigent; (2) the written judgment

erroneously includes a $500 fine because the trial court did not orally pronounce the fine

as part of its sentence; (3) the trial court deprived her of due process of law in ordering

$443.00 to be paid as “reparations” because there is no factual basis for the order; and

(4) the trial court deprived her of due process of law in ordering withdrawal of $2,045.50

from her inmate trust account because there is no factual basis for the amount ordered,

and she was given no opportunity to object to the order. The State agrees the judgment,

Bill of Costs, and order to withdraw funds from Appellant’s inmate account should be

modified as requested. We sustain Appellant’s issues and modify the judgment, Bill of

Costs, and Order Withdrawing Funds From Inmate Trust Account accordingly.

Attorney’s Fees

The record shows Appellant was assessed $787.50 in attorney’s fees. The clerk’s

record includes a July 29, 2025 order finding Appellant had the resources to offset in part

or in whole the costs of the legal services provided to her and ordered her to pay $787.50

in attorney’s fees. The order was issued without a hearing or other inquiry on the record

concerning Appellant’s ability to pay the fees. The same fee is noted in an August 4,

2025 supplement/amendment to conditions of supervision. Appellant’s signature does

not appear on that document.

3 A trial court errs if it orders reimbursement of court-appointed attorney’s fees

without record evidence demonstrating a defendant’s financial resources to offset the

costs of legal services. Mayer v. State, 309 S.W.3d 552, 556 (Tex. Crim. App. 2010).

The record shows Appellant is indigent, and nothing indicates that has changed. Indeed,

the trial court found Appellant indigent three times, twice before the July 29, 2025 order

was entered and once after. Therefore, the remedy is to delete the assessment of

attorney’s fees. See King v. State, No. 07-24-00414-CR, 2025 Tex. App. LEXIS 5849, at

*4–5 (Tex. App.—Amarillo Aug. 6, 2025, no pet.) (mem. op., not designated for

publication) (modifying the judgment to delete assessed attorney’s fees because the

record reflected the appellant did not have a present ability to pay the cost of his court-

appointed attorney’s fees). Accordingly, we modify the Bill of Costs associated with the

judgment to delete $787.50 of attorney’s fees assessed against Appellant.

Fine

The record shows Appellant was assessed a fine of $500.00 at the time she was

placed on deferred adjudication community supervision. The order granting Appellant

deferred adjudication was set aside when the trial court adjudicated her guilty of the

offense. Taylor v. State, 131 S.W.3d 497, 502 (Tex. Crim. App. 2004). Appellant was

not sentenced until her guilt was adjudicated. Id. At that time, the judge did not orally

pronounce a fine but nevertheless included a fine within the written judgment. When

there is a conflict between the oral pronouncement and the written judgment, the oral

pronouncement controls. Id. Because the judge did not orally assess a fine as part of

Appellant’s sentence when guilt was adjudicated, it was incorrectly assessed. Id.

Therefore, we modify the judgment to delete the $500.00 fine.

4 Reparations

The written judgment includes a “special finding” setting forth reparations in the

amount of $443.00. Appellant argues the record does not support the reparations award

and the State agrees. Nothing in the record indicates what this fee represents or why

Appellant owed this fee. While we acknowledge that unpaid community supervision fees

may be included as reparations in judgments adjudicating guilt, there must be some

evidence to support the award. See Taylor v. State, No. 02-15-00425-CR, 2016 Tex.

App. LEXIS 5926, at *10–15 (Tex. App.—Fort Worth June 2, 2016, pet. ref’d) (mem. op.,

not designated for publication) (discussing such fees and evidence to support them). The

record shows only that Appellant was ordered to pay community supervision fees of

$60.00 per month and a $25.00 Crime Stopper Fee within 30 days from the start of her

community supervision. However, Appellant was arrested five days after being placed

on community supervision, and therefore, those fees cannot make up the $443.00

assessed as reparations.

We find the evidence in the record insufficient to support the fees as required. See

Hongpathoum v. State,

Related

Taylor v. State
131 S.W.3d 497 (Court of Criminal Appeals of Texas, 2004)
Mayer v. State
309 S.W.3d 552 (Court of Criminal Appeals of Texas, 2010)
Michael Hongpathoum v. State
578 S.W.3d 213 (Court of Appeals of Texas, 2019)

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