Cameron Moon v. State
2013 Tex. App. LEXIS 9345
| Tex. App. | 2013Background
- Moon, a sixteen-year-old, was charged with murder and certified to stand trial as an adult after juvenile court waiver; district court convicted him of murder and sentenced 30 years.
- Police linked Moon to the shooting through witnesses, texts, and a later confession; ballistics tied a pistol to the bullets.
- Evidence showed Moon’s involvement in a drug-related context and his coconspirator identified him as the shooter.
- At the waiver hearing, the juvenile court relied on section 54.02(f) factors and found Moon lacked prospects for public protection and rehabilitation.
- The appellate court vacated the waiver order, finding insufficient evidence on sophistication, maturity, public protection, and rehabilitation; case dismissed and remanded to juvenile court.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the juvenile court abused its discretion in waiving jurisdiction | Moon argues insufficient support for sophistication, maturity, protection/rehabilitation | State contends factors supported waiver | Abuse of discretion; waiver reversed and case dismissed |
| Whether the court properly applied the sophistication and maturity factor | Moon claims no evidence supports sophistication/maturity | Moon’s messages and conduct show awareness; court properly considered waiver | Evidence legally and factually insufficient to support sophistication/maturity finding |
| Whether the protection of the public and rehabilitation factor supported waiver | Moon had minimal risk and amenable to treatment | Serious offense and background justify waiver | Finding unsupported; not supported by the record; abuse of discretion |
| Whether the district court lacked jurisdiction due to improper waiver | District court lacked jurisdiction; judgment vacated and case dismissed |
Key Cases Cited
- Kent v. United States, 383 U.S. 541 (U.S. 1966) (waiver of jurisdiction is highly important and discretionary with safeguards)
- Hidalgo v. State, 983 S.W.2d 746 (Tex. Crim. App. 1999) (transfer is exceptional; protect juvenile rehabilitation)
- R.E.M. v. State, 541 S.W.2d 841 (Tex. Civ. App.—San Antonio 1976) (sophistication/maturity extends beyond rights waiver to culpability considerations)