Estrada v. State

In Estrada v. State, 594 S.W.2d 445 (Tex. Crim. App. 1980), the Court held that the term reasonable as used in article 44.04(c) encompassed conditions "based upon standards relevant to the purpose of assuring the presence of the defendant." Id. In Estrada, the defendant was convicted of possession of heroin. The Court concluded that the following conditions were reasonable, in other words, rationally related to assuring the defendant's appearance: (1) requiring that the defendant not commit any crimes; (2) requiring the defendant to report to a probation officer; (3) requiring the defendant to report any change of job or address; (4) requiring the defendant to remain within the county unless given permission to leave; (5) requiring the defendant to work faithfully; (6) requiring the defendant to provide urine samples to make sure he was not using illegal drugs and allowing the clinic to report the result to a probation officer; (7) requiring the defendant to attend drug counseling once a month if he began to backslide. Estrada, 594 S.W.2d 445 at 447-48.