Jordan v. State

In Jordan v. State, 54 S.W.3d 783, 786 (Tex. Crim. App. 2001) the Court of Criminal Appeals held that a defendant who had originally been placed on deferred adjudication community supervision could not challenge the voluntariness of his guilty plea by motion for new trial filed after the adjudication of his guilt because a defendant is not allowed to attack his original plea in an adjudication proceeding. (citing Manuel v. State, 994 S.W.2d 658, 661-62 (Tex. Crim. App. 1999)); contra Keller v. State, 854 S.W.2d 224, 227-28 (Tex. App.--Beaumont 1993, pet. ref'd) (addressing merits of post-adjudication motion for new trial alleging newly discovered evidence). Instead, the Court held that a habeas application is the proper means to pursue such an attack. Jordan, 54 S.W.3d at 786.