in the Matter of J.O.E., a Child, 07-15-00215-CV

On April 16, 2015 the State filed a determinate-sentencing petition alleging J.O.E., a 15‑year‑old, committed aggravated robbery and possession of marijuana; the possession count was later waived.
A Potter County grand jury approved and certified the petition on May 6, 2015; the one‑page certification form incorrectly named a different individual in the body though the case style and the attached petition correctly named J.O.E. multiple times.
On May 18, 2015 J.O.E. waived a jury for adjudication, pleaded true to aggravated robbery, and proceeded to disposition without requesting a jury; counsel remained silent during disposition.
The trial court adjudicated J.O.E. delinquent and committed him to the Texas Department of Juvenile Justice for eight years; J.O.E. timely appealed.
On appeal J.O.E. argued (1) the misnamed grand‑jury certification deprived the court of jurisdiction and (2) his right to a disposition‑phase jury was not waived because he was not admonished or did not expressly waive that right.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a grand‑jury certification that names the wrong person in its body voids the court's jurisdiction	The misnomer in the certification makes the certified petition invalid as an indictment; jurisdictional defect can be raised for the first time on appeal	Certification need not be identical to an indictment; the attached petition and case style correctly identified J.O.E., he pleaded true and gave factual admissions, so notice and jurisdiction exist	Error was non‑jurisdictional form defect (misnomer); not objected to at trial; waived on appeal — claim overruled
Whether J.O.E.’s right to a disposition‑phase jury was preserved or required an express written waiver/admonishment	A jury right at disposition cannot be forfeited by inaction; absent an express relinquishment or admonishment, he could not be deemed to have waived it	Family Code requires the juvenile to elect in writing before voir dire for a disposition jury; no such election was made, and no statutory admonition was required	Statute places affirmative duty on the juvenile to request/elect a jury; no request was made — claim overruled

In the Matter of J.G., 905 S.W.2d 676 (Tex. App. — Texarkana 1995) (grand‑jury certified petition treated like an indictment for transfer purposes)
Carrillo v. State, 2 S.W.3d 275 (Tex. Crim. App.) (indictment vests court with jurisdiction)
Cook v. State, 902 S.W.2d 471 (Tex. Crim. App.) (indictment must charge a person and the offense; fundamental defects may void conviction)
Studer v. State, 799 S.W.2d 263 (Tex. Crim. App.) (form defects in an indictment are waivable)
Marin v. State, 851 S.W.2d 275 (Tex. Crim. App.) (discussion of jury‑trial waiver/forfeiture principles)
Wal‑Mart Stores, Inc. v. Alexander, 868 S.W.2d 322 (Tex. 1993) (fundamental error standards)