In re R.G., 388 S.W.3d 820

Relator R.G., a juvenile, was adjudicated delinquent for murder in 1995 at age 14, with a 40-year confinement sentence.
The Fourteenth Court of Appeals affirmed the delinquency adjudication in 1997.
In 2009 Relator filed a habeas corpus petition in the juvenile court alleging ineffective assistance of counsel.
In 2011 the juvenile court granted habeas relief and ordered a new trial after a merits hearing.
Six months later, Relator moved to dismiss for lack of jurisdiction, and the court vacated its habeas relief order and reinstated the delinquency adjudication.
The State sought mandamus relief, and the issue is whether the juvenile court abused its discretion by vacating relief after plenary power expired.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the juvenile court had subject-matter jurisdiction to entertain habeas relief	Relator asserts constitutional jurisdiction as a district court.	State contends the court had only juvenile court limited jurisdiction.	Juvenile court had constitutional jurisdiction to hear habeas petition.

In re Baylor Med. Ctr. at Garland, 280 S.W.3d 227 (Tex. 2008) (trial court may reconsider a timely granted new trial; habeas is separate from pre-trial orders)
In re Brookshire Grocery Co., 250 S.W.3d 66 (Tex. 2008) (voidable after plenary power expires when order voids a prior one)
Ex Parte Valle, 104 S.W.3d 888 (Tex.Crim.App.2003) (civil, not criminal, district courts entertain writs of habeas corpus)
In re Hall, 286 S.W.3d 925 (Tex.2009) (civil district court (also juvenile court) jurisdiction to hear writs of habeas corpus)
Ex Parte Rieck, 144 S.W.3d 510 (Tex.Crim.App.2004) (habeas corpus is a separate proceeding from criminal prosecution)