This question has been addressed in 1 Texas court opinion:
COA14 — February 3, 2026
In Parrish v. State, the Fourteenth Court of Appeals addressed whether a seven-year delay in executing an arrest warrant barred the revocation of community supervision. The appellant asserted a "due diligence" defense; however, the court held that this statutory defense is strictly limited to violations for failure to report or failure to remain in a specified location. Because the State proved a separate violation—failure to provide written employment verification—the court affirmed the revocation, noting that a single proven violation is sufficient. Additionally, the court modified the judgment to remove a fine that was included in the written order but never orally pronounced by the judge, confirming that the oral pronouncement controls in the event of a conflict.
Litigation Takeaway
“A single technical violation of court-ordered supervision, such as failing to provide employment paperwork, is enough to support a revocation regardless of "due diligence" defenses on other counts. Always cross-reference the court's oral ruling against the written judgment to ensure no unauthorized fines or conditions were added.”