Texas Code of Criminal Procedure Section 21 Article 42.12
Code of Criminal Procedure Article 42.12, section 21(b) provides that "at any time during the period of community supervision the judge may issue a warrant for violation of any of the conditions of the community supervision and cause the defendant to be arrested."
On its face, this statute implies that the trial court's authority to revoke a probationer's community supervision ends when the probationary period expires.
The Court held that, under certain circumstances, the trial court may revoke probation after the period expires.
These holdings address the situation in which a probationer is arrested and the revocation hearing is held outside the probationary period.
The Court had long held that a trial court has jurisdiction to hear a motion to revoke in this situation as long as the motion was filed, and a warrant or capias properly issued, during the probationary period. Prior v. State, 795 S.W.2d 179, 184 (Tex. Cr. App. 1990); Stover v. State, 365 S.W.2d 808 (Tex. Cr. App. 1963); Ex parte Fennell, 162 Tex. Crim. 286, 284 S.W.2d 727 (Tex. Cr. App. 1955).