Bell, Kendall, 515 S.W.3d 900

Appellant (age 16) was charged in juvenile court for participation in an aggravated robbery; juvenile court waived jurisdiction in July 2013 and transferred the case to criminal district court.
In criminal court appellant pled guilty (no agreed recommendation); the court deferred adjudication and placed him on community supervision for six years.
About a year later the State filed a motion to adjudicate; the criminal court granted it and adjudicated appellant guilty.
On direct appeal after adjudication, the court of appeals held the juvenile court abused its discretion in waiving jurisdiction because its transfer order lacked adequate case-specific findings under Moon v. State; it vacated the transfer order and criminal judgment and remanded for a new transfer hearing.
The State sought discretionary review, arguing appellant should not be able to attack the 2013 transfer order in an appeal from the later adjudication after revocation — raising jurisdictional bar precedent (Davis, Nix, Manuel) and Tex. Crim. Proc. Code §44.47(b) (as applicable at the time).
The Court of Criminal Appeals granted review limited to whether the court of appeals had jurisdiction to address the transfer-order claim, vacated the court of appeals judgment, and remanded for that court to address jurisdiction first; other grounds were refused.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether appellant may attack the juvenile transfer order on appeal from an adjudication after revocation of deferred adjudication	Bell argued Moon error in the transfer order is reviewable on this appeal and warranted vacatur	State argued such collateral attack is barred; the proper time was direct appeal from the transfer/deferred-adjudication order and jurisdictional rules prohibit review now	Court vacated court of appeals judgment and remanded for that court to decide jurisdiction in the first instance; directed jurisdictional question be addressed first
Whether the court of appeals had authority to reach the merits before addressing jurisdiction	Bell implicitly proceeded to merits on Moon error	State contended the court of appeals lacked jurisdiction and should have dismissed without reaching merits	CCA agreed jurisdiction must be vetted first and remanded for the court of appeals to consider jurisdiction before merits

Moon v. State, 451 S.W.3d 28 (Tex. Crim. App. 2014) (juvenile transfer orders require adequate case-specific findings)
Davis v. State, 195 S.W.3d 708 (Tex. Crim. App. 2006) (limits on collateral attacks after adjudication/revocation)
Nix v. State, 65 S.W.3d 664 (Tex. Crim. App. 2001) (jurisdictional dismissal where appeal was improper vehicle)
Manuel v. State, 994 S.W.2d 658 (Tex. Crim. App. 1999) (appeal dismissed for lack of jurisdiction when wrong procedural posture used)
Daniels v. State, 30 S.W.3d 407 (Tex. Crim. App. 2000) (same jurisdictional dismissal principle)
Henson v. State, 407 S.W.3d 764 (Tex. Crim. App. 2013) (jurisdiction is an absolute systemic requirement)
Skinner v. State, 484 S.W.3d 434 (Tex. Crim. App. 2016) (appellate courts must review jurisdiction regardless of party arguments)