Justia Juvenile Law Opinion Summaries

Articles Posted in Texas Court of Criminal Appeals
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After Appellant Cameron Moon was certified in juvenile court to stand trial as an adult, the juvenile court ordered his case transferred to the district court for adult criminal proceedings. Appellant then filed a pretrial application of writ of habeas corpus challenging the transfer. The district court denied relief, so Appellant took an interlocutory appeal. The Court of Appeals reversed the district court’s order denying relief, concluding the State had failed to establish the necessary statutory criteria for waiver of juvenile jurisdiction and transfer into the adult criminal court. As a result, the appellate court remanded the case with instructions to dismiss the prosecution for lack of jurisdiction. The Texas Court of Criminal Appeals granted the State's petition for discretionary review to consider several issues related to the juvenile court's transfer order including whether the court of appeals erred to hold that such a challenge was even cognizable in pretrial habeas. However, the Court concluded that, even if Appellant’s claims were cognizable in a pretrial habeas proceeding, the court of appeals lacked the authority to entertain Appellant’s interlocutory appeal. Accordingly, the Court of Criminal Appeals reversed the court of appeals’ judgment and remanded to that court for an order dismissing Appellant’s appeal as premature. View "Ex parte Moon" on Justia Law

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Applicant Steven Thomas was 16 when he committed capital murder. When he was 19, the juvenile court waived its exclusive jurisdiction and transferred Applicant’s case to district court, where Applicant pleaded guilty to a lesser charge of murder. Decades passed. Applicant did not appeal his transfer or his case or file a writ of habeas corpus. Then, the Texas Court of Criminal Appeals decided Moon v. Texas, 451 S.W.3d 28 (Tex. Crim. App. 2014), which held that if an order waiving juvenile jurisdiction did not contain factually-supported, case-specific findings, then the order is invalid, and the district court never acquires jurisdiction. Based upon Moon, Applicant argued that because the order waiving juvenile jurisdiction did not contain factually-supported, case-specific findings, it was invalid, and thus the district court never acquired jurisdiction. The Court of Criminal Appeals found that the type of findings Moon required were neither grounded in the text of the transfer statute, nor in Kent v. United States, 383 U.S. 541 (1966), the Supreme Court precedent that it purportedly relied upon in Moon. "Requiring them may be good policy, but the lack of case-specific findings has nothing to do with jurisdiction, fundamental constitutional rights, or even the transfer statute itself. The juvenile court’s transfer order in this case may have lacked factually-supported, case-specific findings, but that did not make that order invalid or deprive the district court of jurisdiction." Consequently, the Court determined Applicant was not entitled to habeas corpus relief. View "Ex parte Steven Thomas" on Justia Law

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Appellant Michael Herring was 16 years old when he was arrested for, and charged with, aggravated robbery. Because he was a juvenile, he was given his Miranda warnings by a magistrate. There was conflicting testimony as to whether two armed police officers were present when appellant was given these warnings. After the warnings, appellant was questioned by two police officers, and he confessed to the charged robbery, as well as other robberies and burglaries. The confession was reduced to writing by one of the officers, and appellant signed it. At trial, appellant filed a motion to suppress the signed statement, and argued, among other things, that the statement was taken in violation of Family Code Section 51.095 because armed law-enforcement officers were present when he was given the magistrate's warnings. The motion was denied, and a jury found appellant guilty, sentencing him to 20 years' confinement. Appellant appealed and asserted that the trial court erred in denying the motion to suppress. The court of appeals affirmed appellant's conviction. Appellant argued one issue to the Supreme Court: whether Section 51.095(a)(1)(A) permitted law-enforcement officers to be present when a juvenile is initially read his rights. The Court concluded that Section 51.095(a)(1)(A) does not prohibit the presence of law-enforcement officers, and accordingly affirmed. View "Herring v. Texas" on Justia Law