In the Matter of J.A.R., a Juvenile, 343 S.W.3d 504

Appellant J.A.R. is a juvenile who faced a determinate sentence for indecency with a child; the State filed a petition in 2008 and a grand jury approved it.
Appellant waived a jury trial and pled true pursuant to a plea bargain; the trial court adjudicated and committed him to TYC for a ten-year determinate sentence.
On March 19, 2010, TYC requested a release/transfer hearing under Texas Family Code § 54.11 to determine whether J.A.R. should be transferred to TDCJ.
Following the hearing, the court transferred J.A.R. from TYC to TDCJ to serve the remainder of his sentence.
Evidence included psychiatric/psychological evaluations, treatment history at TYC, and recommendations by TYC personnel that transfer to TDCJ was appropriate due to risk of future assaultive conduct.
The appellate court upheld the transfer, finding some evidence supporting the court’s decision and affirming the trial court’s order.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the transfer to TDCJ was an abuse of discretion	J.A.R. contends abuse of discretion	TYC/State contends evidence supported transfer	No abuse; transfer affirmed

In re D.L., 198 S.W.3d 228 (Tex.App.—San Antonio 2006) (abuse-of-discretion standard; record viewed as a whole)
In re J.M.O., 980 S.W.2d 811 (Tex.App.—San Antonio 1998) (some evidence suffices to transfer juvenile to TDCJ)
In re R.G., 994 S.W.2d 309 (Tex.App.—Houston [1st Dist.] 1999) (appellate review limited to whether court acted with reference to guiding rules)
In re J.L.C., 160 S.W.3d 312 (Tex.App.—Dallas 2005) (court may weigh factors and consider other relevant factors; not required to prove all)