Rodriguez, Isaac Nathaniel

CourtCourt of Appeals of Texas
DecidedDecember 18, 2015
DocketPD-1365-15
StatusPublished

This text of Rodriguez, Isaac Nathaniel (Rodriguez, Isaac Nathaniel) 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
Rodriguez, Isaac Nathaniel, (Tex. Ct. App. 2015).

Opinion

/U5-/S

NO. PD-1365-15 ORIGINAL IN THE

COURT OF CRIMINAL APPEALS

OF TEXAS

ISAAC NATHANIEL RODRIGUEZ FILED IN Appellant RECEIVED IN COURT OF CRIMINAL APPEALS C0URT 0F CRIMINAL APPEALS C£1GZ::3 vs- DEC 18 2015

Abel Acosta, Clerk ™E STATCOFTEXAS Abe! Acosfa, Clerk

Petition in Cause No. 2013-CR-2038 From the 386th District Court ofBexar County, Texas, And Appeal No. 04-15-00108-CR From the Court of Appeals for the Fourth Court of Appeals District of Texas

PETITION FOR DISCRETIONARY REVIEW

ORAL ARGUMENT REQUESTED ISAAC N. RODRIGUEZ PROSE TDC #1984841 Garza West Unit 4250 HWY 202 Beeville, Texas 78102-8982

APPELLANT Identity of Parties and Counsel

Pursuant to TEX. R. APP. P. 38.1(a), the parties to this suit are as

follows:

(1) Isaac Nathaniel Rodriguez, TDCJ #1984841, Garza West Unit,

4250 HWY 202, Beeville, Texas 78102-8982, is the appellant and was the

defendant in trial court.

(2) The State of Texas, by and through the Bexar County District

Attorney's Office, Paul Elizondo Tower, 101 W. Nueva St., San Antonio,

Texas 78205, is the appellee and prosecuted this case in the trial court.

The trial attorneys were as follows:

(1) Isaac Nathaniel Rodriguez, was represented by John Young,

and Scott Hill, 111 Soledad St. Ste 300, San Antonio, TX 78205.

(2) The State of Texas was represented by Susan D. Reed (succeeded

by Nicholas Lahood), District Attorney, and Jill Mata, and Khristina

Fielder, Assistant District Attorneys, 235 E. Mitchell Rd., San Antonio, ( Texas 78210. Ms. Mata has since become the Texas Juvenile Justice

Department General Counsel, P.O. Box 12757, Austin, Texasn7871 1.

The appellate attorneys are as follows:

n (1) Isaac Nathaniel Rodriguez is represented by Michael D.

Robbins, Assistant Public Defender, Paul Elizondo Tower, 101 W. Nueva

St., Suite 310, San Antonio, Texas 78205.

(2) The State of Texas is represented by the Nathan Morey, Assistant

District Attorney, Appellate Division, Paul Elizondo Tower, 101 W. Nueva

St., Suite 710, San Antonio, Texas 78205.

The trial judge was Hon. Laura Parker, 386 District Court, 235 E.

Mitchell Rd., San Antonio, Texas 78210.

The Fourth Court of Appeals decided this case in a panel consisting of

Hon. Patricia O. Alvarez, Hon. Luz Alena D. Chapa, and Hon. Jason

Pulliam, Associate Justices, Fourth Court of Appeals, Cadena-Reeves

Justice Center, 300 Dolorosa St., Suite 3200, San Antonio, Texas 78205.

The opinion was written by Hon. Patricia O. Alvarez

in Table of Contents

Identities of Parties and Counsel ii

Table of Contents..., iv

Index of Authorities v

A Note Regarding Record References vi

Introduction 1

Statement Regarding Oral Argument 1

Statement of the Case 1

Statement of Procedural History 2

Ground for Review 2

GROUND FOR REVIEW

The court of appeals erred when it found that the juvenile court's order of waiver and transfer to criminal court was sufficient, because the order was generic boilerplate and was not case-specific, as required by Moon v. State, 451 S.W.3d 28 (Tex. Crim. App. 2014).

Argument 3

Prayer for Relief. .. 11

Certificate of Service 12

Word Count Certification. . .. 12

Appendix. ••• •• 12

iv Index of Authorities

Statutes

TEX. CODE CRIM. PROC. art. 44.47. 3

TEX. FAM. CODE § 54.02 4

TEX. FAM. CODE § 56.02 5

TEX. PENAL CODE § 19.02 3

Rules

TEX.R.APP.P.9.4 12

TEX.R.APP.P.9.5. 12

TEX.R.APP.P.38.1 ii

TEX.R.APP.P.66.3 3

TEX.R.APP.P.68.2 12

TEX. R. APP. P. 68.11 12

Cases

Bleys v. State, 319 S.W.3d 857 (Tex. App. -San Antonio 2010, no pet.)..

Faisst v. State, 105 S.W.3d 7 (Tex. App. - Tyler 2003, no pet.)

Rodriguez v. State, No. 04-14-00352-CR, 2015 Tex. App. LEXIS 4571 (Tex. App. - San Antonio May 6, 2015, pet. filed)(designated for publication)

Moon v. State, 452 S.W.3d 28 (Tex. Crim. App. 2014) A Note Regarding Record References

In this brief, references to the six-volume reporter's record will be

thus: (RR ); and to the clerk's record will be thus: (CR ).

VI TO THE COURT OF CRIMINAL APPEALS OF TEXAS:

ISAAC N. RODRIGUEZ petitions this Honorable Court to review the

judgment affirming his conviction for murder in Cause No. 2013-CR-2038.

Statement Regarding Oral Argument

The Appellant, ISAAC N. RODRIGUEZ, requests oral argument

before'the Court of Criminal Appeals of Texas, because oral argument will

assist the Court in determining whether the court of appeals erred when it

determined that the order of waiver ofjuvenile jurisdiction and transfer to

criminal court was sufficiently detailed in light of this Honorable Court's

opinion m Moon v. State, 451 S.W.3d. 28 (Tex. Crim. App. 2014).

Statement of the Case

The Appellant was charged as a juvenile with the offense of murder.

The juvenile court waived itsjurisdiction and transferred the case to criminal

court. Appellant was indicted for capital murder. He pleaded guilty to the

charge of murder under a plea bargain, and was sentenced by the trial court

to 30 years in the Texas Department of Criminal Justice. The Court of

Appeals for the Fourth Court of Appeals District of Texas affirmed the

judgment and sentence, on Sept. 16, 2015, in an opinion designated for

publication. Statement of Procedural History

A three-justice panel of the court of appeals rendered its opinion on

Sept. 16, 2015 Rodriguez v. State, No. 04-15-00108-CR, 2015 (Tex. App. -

San Antonio) (designated for publication). No motion for rehearing was

filed by Appellant. Pursuant to Rule 68.2(a) of the Texas Rules of Appellate

Procedure, this petition is e-filed with the clerk of the Court of Criminal

Appeals within ninety (90) days after the judgment of the Court was

rendered, on Sept. 16, 2015.

The court of appeals erred when it found that the juvenile court's

order of waiver and transfer to criminal court was sufficient, because the

order was generic boilerplate and was not case-specific, as required by Moon

v. State, 451 S.W.3d 28 (Tex. Crim. App. 2014). Argument

Introduction.

This criminal case began as a juvenile case. On October 24, 2012,

the State filed a petition for waiver ofjurisdiction and discretionary transfer

to criminal court in Cause No. 2012-JUV-01710, charging ISAAC N.

RODRIGUEZ, with murder. (CR, 11). The case proceeded to certification

hearing on the State's petition. Following a contested hearing, the juvenile

court waived its jurisdiction and transferred this case to criminal court. (CR,

40;RR68).

Mr. Rodriguez was subsequently indicted for capital murder, in Cause

No. 2013-CR-2038. (CR, 47). Appellant pleaded guilty to the

charge of murder, with a plea bargain. (RR,3,1)/

The trial court sentenced Mr. Rodriguez to 30 years

imprisonment. (CR, 331,337). The trial court correctly certified that

this is a plea bargained case but that Mr. Rodriguez has the right to appeal

pretrial orders. (CR, 331).Mr. Rodriguez timely filed notice of appeal.

(CR, 336).

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Related

Faisst v. State
105 S.W.3d 7 (Court of Appeals of Texas, 2002)
Faisst v. State
105 S.W.3d 8 (Court of Appeals of Texas, 2003)
Bleys v. State
319 S.W.3d 857 (Court of Appeals of Texas, 2010)
McKaine v. State
170 S.W.3d 285 (Court of Appeals of Texas, 2005)
Jonathan Albert Leal v. State
452 S.W.3d 14 (Court of Appeals of Texas, 2014)
Jorge Guerrero v. State
471 S.W.3d 1 (Court of Appeals of Texas, 2014)
Moon, Cameron
451 S.W.3d 28 (Court of Criminal Appeals of Texas, 2014)
John Gonzalez III v. State
467 S.W.3d 595 (Court of Appeals of Texas, 2015)
M.A., Matter Of
935 S.W.2d 891 (Court of Appeals of Texas, 1996)

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