In the Matter of A.F. v. the State of Texas

CourtCourt of Appeals of Texas
DecidedFebruary 22, 2024
Docket02-23-00457-CV
StatusPublished

This text of In the Matter of A.F. v. the State of Texas (In the Matter of A.F. v. the State of Texas) is published on Counsel Stack Legal Research, covering Court of Appeals of Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In the Matter of A.F. v. the State of Texas, (Tex. Ct. App. 2024).

Opinion

In the Court of Appeals Second Appellate District of Texas at Fort Worth ___________________________ No. 02-23-00457-CV ___________________________

IN THE MATTER OF A.F.

On Appeal from the 323rd District Court Tarrant County, Texas Trial Court No. 323-121996-23

Before Sudderth, C.J.; Kerr and Birdwell, JJ. Memorandum Opinion by Chief Justice Sudderth MEMORANDUM OPINION

Appellant A.F. (Arnold)1 is accused of committing capital murder when he was

15 years old by shooting and attempting to rob his Lyft driver. See Tex. Penal Code

Ann. § 19.03(a)(2). He appeals the juvenile court’s order waiving its jurisdiction and

transferring his case to the criminal courts for his prosecution as an adult.2 See Tex.

Fam. Code Ann. §§ 54.02(a), 56.01(c)(1)(A), (h-1). In his sole appellate issue, Arnold

claims that the transfer order was an abuse of the juvenile court’s discretion because

“the weight of the evidence” regarding his sophistication and maturity “established

[that] TJJD3 was the best placement option” for him. See id. § 54.02(f) (requiring

consideration of four factors, including “the sophistication and maturity of the

child”). Because we reject the merits of his argument as well as the implied premises

upon which it is based, we will affirm.4

I. Governing Law

A juvenile court may waive its exclusive original jurisdiction and transfer a child

to the appropriate district court or criminal district court for criminal proceedings if,

1 We use a pseudonym to protect the juvenile’s identity. See Tex. Fam. Code Ann. § 56.01(j); Tex. R. App. P. 9.8(c). 2 When the transfer order was signed, Arnold was 16 years old. 3 TJJD refers to the Texas Juvenile Justice Department. 4 This interlocutory appeal is subject to an accelerated, 180-day deadline for disposition. Tex. R. Jud. Admin. 6.2(a)

2 among other things, “the juvenile court determines [1] that there is probable cause to

believe that the child before the court committed the offense alleged and [2] that

because of the seriousness of the offense alleged or the background of the child the

welfare of the community requires criminal proceedings.” Id. § 54.02(a)(3); see In re

T.S., No. 02-20-00353-CV, 2021 WL 733305, at *2 (Tex. App.—Fort Worth Feb. 25,

2021, no pet.) (mem. op.). The State has the burden to persuade the juvenile court to

transfer the case by a preponderance of the evidence. In re C.F., No. 02-22-00195-

CV, 2022 WL 4545566, at *1 (Tex. App.—Fort Worth Sept. 29, 2022, no pet.) (mem.

op.). In deciding whether a preponderance of the evidence supports the second

requirement, the juvenile court must consider four nonexclusive statutory factors:

(1) “whether the alleged offense was against person or property”; (2) the record and

previous history of the juvenile; (3) “the prospects of adequate protection of the

public and the likelihood of the [juvenile’s] rehabilitation” through the juvenile-justice

system; and (4) the juvenile’s “sophistication and maturity.”5 Tex. Fam. Code Ann.

§ 54.02(f); see C.F., 2022 WL 4545566, at *1; In re A.K., No. 02-20-00410-CV, 2021

WL 1803774, at *19 (Tex. App.—Fort Worth May 6, 2021, pet. denied) (mem. op.);

T.S., 2021 WL 733305, at *2. “[A]ny combination of these [factors] may suffice to

support a waiver of jurisdiction and transfer.” C.F., 2022 WL 4545566, at *1 (citing

A.K., 2021 WL 1803774, at *19).

5 We have reordered the statutory factors to match the sequence of our analysis.

3 II. Standard of Review

Generally, a juvenile court’s transfer order is subject to a two-pronged review:

first we review the juvenile court’s specific fact-findings under the traditional

evidentiary-sufficiency standards, then we review the juvenile court’s transfer decision

for an abuse of discretion. In re J.D., No. 02-23-00177-CV, 2023 WL 6152620, at *4

(Tex. App.—Fort Worth Sept. 21, 2023, pet. denied) (mem. op.); A.K., 2021 WL

1803774, at *18.

If the juvenile court’s findings are challenged for factual insufficiency, we

consider all evidence presented to determine if the challenged findings are against the

great weight and preponderance of the evidence so as to be clearly wrong and unjust.

A.K., 2021 WL 1803774, at *18; T.S., 2021 WL 733305, at *3.

As for whether the transfer decision was an abuse of discretion, a juvenile court

abuses its discretion if, in light of the evidence presented, the decision is arbitrary or

made without reference to the statutory criteria. J.D., 2023 WL 6152620, at *4; C.F.,

2022 WL 4545566, at *1; A.K., 2021 WL 1803774, at *18; T.S., 2021 WL 733305, at

*3. Because the juvenile court sits as factfinder and evaluates the witnesses in person,

it is the sole judge of the credibility of the witnesses and the weight to be given their

testimony. T.S., 2021 WL 733305, at *3. The juvenile court may resolve conflicts in

the evidence, and as long as its transfer decision is supported by some substantive and

probative evidence and reflects “a reasonably principled application of the legislative

criteria,” it is not an abuse of discretion. C.F., 2022 WL 4545566, at *1–2.

4 III. Discussion

Arnold argues that the juvenile court abused its discretion by transferring his

case because the weight of the evidence—specifically, the evidence of his immaturity

and lack of sophistication, one of the four statutory factors—showed that he “would

be better served by . . . being adjudicated through the juvenile system.” This

argument is flawed.

A. Arnold’s best interest is not the question.

First, the juvenile court was not asked to determine whether Arnold would be

“better served” by the juvenile-justice system. Rather, the juvenile court was asked to

determine whether “the welfare of the community requires criminal proceedings” and

to consider whether the juvenile-justice system could provide “adequate protection

[for] the public and [a] likelihood of [Arnold’s] rehabilitation.” Tex. Fam. Code Ann.

§ 54.02(a)(3), (f)(4). Arnold’s best interest was not the question, so even if Arnold

“would be better served” by the juvenile system, that would not have made the

juvenile court’s transfer order an abuse of discretion. We overrule Arnold’s issue to

the extent that it relies on this faulty premise.

B. Not every statutory factor need favor transfer.

Another faulty premise seemingly underlying Arnold’s appellate argument is his

claim that the “weight of the evidence” was against transfer based on just one of the

four statutory factors: according to Arnold, the evidence showed that his “immaturity

5 and sophistication would be better served by him being adjudicated through the

juvenile system.”

But even if the evidence of Arnold’s “sophistication and maturity” weighed

against transfer, that would not necessarily have made transfer an abuse of discretion,

as there are four statutory factors, id. § 54.02(f)(2), and no one factor is vital to the

juvenile court’s decision so long as there is sufficient evidence overall. J.D., 2023 WL

6152620, at *4 (noting that juvenile court “does [not] need to find that the evidence

establishes each factor”); A.K., 2021 WL 1803774, at *23 n.19 (“[T]here need not be

evidence in support of every Section 54.02(f) factor weighing in favor of transfer, so

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Related

§ 54.02
Texas FA § 54.02(a)(3)
§ 56.01
Texas FA § 56.01(j)
§ 19.03
Texas PE § 19.03(a)(2)

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