In the Matter of L. H. v. the State of Texas

CourtCourt of Appeals of Texas
DecidedNovember 7, 2024
Docket01-24-00366-CV
StatusPublished

This text of In the Matter of L. H. v. the State of Texas (In the Matter of L. H. 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 L. H. v. the State of Texas, (Tex. Ct. App. 2024).

Opinion

Opinion issued November 7, 2024

In The

Court of Appeals For The

First District of Texas ———————————— NO. 01-24-00366-CV ——————————— IN THE MATTER OF L.H., a Juvenile

On Appeal from the 313th District Court Harris County, Texas Trial Court Case No. 2021-00856J

MEMORANDUM OPINION

In this accelerated appeal,1 appellant, L.H., challenges the juvenile court’s

order, entered after a transfer hearing, waiving its exclusive original jurisdiction over

his case and transferring it to a criminal district court for L.H. to be tried as an adult

1 See TEX. FAM. CODE ANN. § 56.01(c)(1)(A), (h) (providing right to immediate appeal from order “respecting transfer of [a] child for prosecution as an adult” and instructing that appeal from such order has “precedence over all other cases”); see also TEX. R. APP. P. 28.1. for the felony offense of murder.2 In two issues, L.H. contends that the juvenile

court lacked jurisdiction to transfer his case to a criminal district court and the

juvenile court, assuming it had jurisdiction, erred in waiving its exclusive original

jurisdiction and transferring his case to a criminal district court.

We reverse and remand.

Background

On May 25, 2021, the State filed its original petition alleging that L.H., at the

age of sixteen, had engaged in delinquent conduct by “intentionally and knowingly

caus[ing] the death of Matthew Vu, [the complainant], by shooting the complainant

with a firearm.” (Emphasis omitted.) The State further alleged that L.H. had

engaged in delinquent conduct by “intend[ing] to cause serious bodily injury to [the

complainant]” and “caus[ing] the death of the [c]omplainant by intentionally and

knowingly committing an act clearly dangerous to human life, namely shooting the

complainant with a firearm.” (Emphasis omitted.) In its original petition, the State

requested that L.H. “be adjudged a child who ha[d] engaged in delinquent conduct

and be provided for as the law direct[ed].”

On January 14, 2022, the State filed its first amended petition, alleging the

same delinquent conduct and requesting, pursuant to Texas Family Code section

54.02(a), that the juvenile court waive its exclusive original jurisdiction over L.H.’s

2 See TEX. PENAL CODE ANN. § 19.02.

2 case and transfer it to a criminal district court for L.H. to stand trial as an adult for

the felony offense of murder.3 The State also filed a motion to waive jurisdiction.

On July 25, 2022, the juvenile court held a transfer hearing on the State’s

request.4 At the conclusion of the transfer hearing, the juvenile court denied the

State’s request to waive its jurisdiction and transfer L.H.’s case to criminal district

court.

On July 27, 2022, the State filed its second amended petition, again alleging

the same delinquent conduct and requesting requested that L.H. “be adjudged a child

who ha[d] engaged in delinquent conduct and be provided for as the law direct[ed].”

The second amended petition was approved by a Harris County grand jury for

determinate sentencing.5 Also, on July 27, 2022, L.H. turned eighteen years old.

Because L.H. had turned eighteen years old, on July 17, 2023, the juvenile

court held a hearing to determine if it could retain jurisdiction over L.H.’s case

3 See TEX. FAM. CODE ANN. § 54.02(a) (juvenile court may waive its exclusive original jurisdiction and transfer a child to appropriate district court or criminal district court if certain conditions are met). 4 See id. § 54.02(c) (juvenile court “shall conduct a hearing without a jury to consider transfer of the child for criminal proceedings”); see also id. § 54.02(e) (at transfer hearing, juvenile court may consider “written reports from probation officers, professional court employees, guardians ad litem . . . or professional consultants in addition to the testimony of witnesses”). 5 See generally In re X.A., No. 01-19-00227-CV, 2020 WL 237939, at *1 n.2 (Tex. App.—Houston [1st Dist.] Jan. 16, 2020, orig. proceeding) (mem. op.) (explaining “the determinate sentence system”).

3 pursuant to Texas Family Code section 51.0412.6 At the conclusion of the hearing,

the juvenile court entered a finding that the State had used due diligence in

attempting to complete the proceedings before L.H.’s nineteenth birthday and

concluded that section 51.0412 authorized it to retain jurisdiction over L.H.’s case.

L.H. turned nineteen years old on July 27, 2023.

On January 4, 2024, the State filed its third amended petition, alleging the

same delinquent conduct. In its third amended petition, the State requested, pursuant

to Texas Family Code section 54.02(j), that the juvenile court waive its exclusive

original jurisdiction over L.H.’s case and transfer it to a criminal district court for

L.H. to stand trial as an adult for the felony offense of murder.7 The State also filed

a motion to waive jurisdiction relying on Texas Family Code section 54.02(j).

6 See TEX. FAM. CODE ANN. § 51.0412 (“Jurisdiction Over Incomplete Proceedings”); see also In re B.R.H., 426 S.W.3d 163, 166–67 (Tex. App.— Houston [1st Dist.] 2012, no pet.) (“A juvenile court has exclusive, original jurisdiction over all proceedings involving a person who has engaged in delinquent conduct as a result of acts committed before age seventeen. A juvenile court does not lose jurisdiction when a juvenile turns eighteen, but its jurisdiction becomes limited. The juvenile court retains limited jurisdiction to either transfer the case to an appropriate court or dismiss the case. However, . . . Texas Family Code [section 51.0412] provides an exception to this rule, which applies to incomplete proceedings.” (internal citations omitted)). 7 See TEX. FAM. CODE ANN. § 54.02(j) (providing juvenile court “may waive its exclusive original jurisdiction and transfer a person to [a] . . . criminal district court for criminal proceedings if: (1) the person is 18 years of age or older; (2) the person was . . . 10 years of age or older and under 17 years of age at the time the person is alleged to have committed . . . an offense under” Texas Penal Code section 19.02; “(3) no adjudication concerning the alleged offense has been made or no adjudication hearing concerning the offense has been conducted; (4) the juvenile court finds from a preponderance of the evidence that . . . for a reason beyond the 4 On April 1, 2024, the juvenile court held a transfer hearing on the State’s

request. At the transfer hearing, Houston Police Department (“HPD”) Detective L.

Lange testified that he investigated the shooting of the complainant, which occurred

at the Shabu Zone restaurant in Houston, Harris County, Texas. According to Lange,

the complainant was L.H.’s stepfather.

Detective Lange explained that after the shooting, he arrived at the restaurant,

and other law enforcement officers were already at the scene. Lange was directed

to a private dining area in the back of the restaurant where the complainant was lying

on the ground. The complainant was face up and had a large pool of blood on the

floor around him; he was deceased. The complainant had sustained a gunshot wound

to his head, which was caused by a firearm. Law enforcement officers found a

cartridge casing in the private dining area.8

According to Detective Lange, the complainant’s family, including L.H., were

eating dinner at the restaurant in the private dining area. At some point, L.H. got out

a firearm from his jacket and shot the complainant in the back of the head. L.H. then

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Texas a & M University System v. Koseoglu
233 S.W.3d 835 (Texas Supreme Court, 2007)
Jones v. State
175 S.W.3d 927 (Court of Appeals of Texas, 2005)
Texas Ass'n of Business v. Texas Air Control Board
852 S.W.2d 440 (Texas Supreme Court, 1993)
Laidlaw Waste Systems (Dallas), Inc. v. City of Wilmer
904 S.W.2d 656 (Texas Supreme Court, 1995)
Dubai Petroleum Co. v. Kazi
12 S.W.3d 71 (Texas Supreme Court, 2000)
AMX Enterprises, Inc. v. Bank One, N.A.
196 S.W.3d 202 (Court of Appeals of Texas, 2006)
City of San Antonio v. City of Boerne
111 S.W.3d 22 (Texas Supreme Court, 2003)
Faisst v. State
105 S.W.3d 8 (Court of Appeals of Texas, 2003)
State v. Holcombe
187 S.W.3d 496 (Court of Criminal Appeals of Texas, 2006)
Fleming Foods of Texas, Inc. v. Rylander
6 S.W.3d 278 (Texas Supreme Court, 1999)
Kawasaki Steel Corp. v. Middleton
699 S.W.2d 199 (Texas Supreme Court, 1985)
John Thompson v. Texas Department of Licensing and Regulation
455 S.W.3d 569 (Texas Supreme Court, 2014)
in Re Mark Fisher and Reece Boudreaux
433 S.W.3d 523 (Texas Supreme Court, 2014)
in the Interest of B.N.F. and J.D.F., Jr., Children
120 S.W.3d 873 (Court of Appeals of Texas, 2003)
In the Matter of E.D.C., a Juvenile
88 S.W.3d 789 (Court of Appeals of Texas, 2002)
in Re B.R.H.
426 S.W.3d 163 (Court of Appeals of Texas, 2012)
in Re National Lloyds Insurance Company
507 S.W.3d 219 (Texas Supreme Court, 2016)
In re A.S.
875 S.W.2d 402 (Court of Appeals of Texas, 1994)
Matter of M.A.V.
954 S.W.2d 117 (Court of Appeals of Texas, 1997)

Cite This Page — Counsel Stack

Bluebook (online)
In the Matter of L. H. v. the State of Texas, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-the-matter-of-l-h-v-the-state-of-texas-texapp-2024.