Aarron Jacob Moore v. State, 446 S.W.3d 47

Moore, born July 11, 1992, committed aggravated sexual assault of a child in 2008 at age 16.
The alleged offense occurred August 29, 2008; the victim identified Moore on September 19, 2008.
Detective Cox delayed forwarding the case due to an internal birthday error listing Moore as younger than he was, and due to a heavy caseload.
On August 17, 2011 the State petitioned for discretionary transfer from juvenile court to criminal district court; the juvenile court transferred on February 10, 2012, finding a reason beyond the State's control for not proceeding before Moore’s eighteenth birthday.
Moore pleaded guilty under a plea agreement; the criminal district court deferred adjudication and placed him on five years’ community supervision.
The issue on appeal is whether the juvenile court properly transferred the case, given the State’s failure to prove a reason beyond the State’s control under Tex. Fam. Code Ann. § 54.02(j)(4)(A).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the transfer complied with Tex. Fam. Code Ann. § 54.02(j)(4)(A).	Moore argues no valid reason beyond the State’s control.	State contends delay due to investigative considerations was beyond its control.	Juvenile court erred; State failed to show reason beyond its control.

In re B.R.H., 426 S.W.3d 163 (Tex. App.—Houston [1st Dist.] 2012) (jurisdictional transfer standards under 54.02(j))
In re N.J.A., 997 S.W.2d 554 (Tex. 1999) (due diligence and applicability of 54.02(j) to transfer decisions)
In re J.C.C., 952 S.W.2d 47 (Tex. App.—San Antonio 1997) (deference to juvenile court findings and transfer framework)
In re M.A., 935 S.W.2d 891 (Tex. App.—San Antonio 1996) (jurisdictional scope of juvenile court post-18 and transfer authority)
State v. Lopez, 196 S.W.3d 872 (Tex. App.—Dallas 2006) (abuse-of-discretion review of juvenile transfer decisions)