Background
Christopher Daniel Beltran was indicted on two counts of burglary of a habitation. The trial court deferred adjudication and placed Beltran on community supervision, requiring him to participate in residential treatment at a Substance Abuse Felony Punishment Facility (SAFPF). After completing the initial program, Beltran relapsed and was ordered to enter the SAFPF Relapse program.
Following his release from the Relapse program, Beltran was placed in an aftercare transitional center but subsequently left the facility. The State then moved to adjudicate Beltran’s guilt and revoke his community supervision. On March 25, 2025, the trial court adjudicated Beltran guilty on both counts and sentenced him to concurrent ten-year prison terms.
The Court’s Holding
The trial court awarded Beltran 977 days of credit for time served in federal custody but failed to provide credit for the periods he served at the SAFPF and SAFPF Relapse programs. Beltran appealed, claiming entitlement to an additional 344 days of credit under Texas Code of Criminal Procedure Article 42A.755(d), which requires trial courts to credit time served as a condition of community supervision in approved substance abuse facilities when the defendant successfully completes the treatment program.
The State conceded error on appeal. The court sustained Beltran’s sole issue and reversed and remanded the matter to the trial court to reform the judgments to include the complete credit for all time served at the SAFPF and SAFPF Relapse facilities.
Key Takeaways
- Defendants on community supervision must receive statutory credit for time served in SAFPF programs upon successful completion
- Trial courts must account for all qualifying time served when calculating sentences on revocation of community supervision
- Failure to award mandatory statutory credit requires reversal and remand for correction
Why It Matters
This decision reinforces that trial courts cannot omit statutorily mandated credit for time served in substance abuse treatment facilities. The ruling protects defendants’ rights under Article 42A.755(d) and ensures proper sentence calculations on revocation of deferred adjudication.
For practitioners, the decision underscores the importance of tracking and advocating for all applicable time credit during community supervision proceedings and sentencing on revocation, as trial courts may overlook residential treatment periods even when the defendant complies with the program requirements.