in the Matter of J.Y., 02-17-00092-CV

Juvenile J.Y. stipulated to aggravated robbery with a deadly weapon in Dec. 2016 and was adjudicated delinquent; trial court imposed a 10-year TJJD term, probated for five years, and released him from detention.
The same day he was released, J.Y. was arrested after fleeing from police in a stolen vehicle; a firearm was left in the vehicle. The State moved to modify his disposition for probation violations (fleeing, marijuana use/positive test).
At the March 2017 modification hearing, the court received stipulations, live testimony from probation officers and Officer Cannon, a social-history study, and a psychological evaluation recommending a structured residential setting and supervision.
Probation testimony indicated the mother could not adequately supervise J.Y., he associated with delinquent peers, used drugs daily, and had anger and school-attendance problems; a Pennsylvania residential school was available but located over 1,000 miles away.
The trial court found J.Y. had violated probation, determined reasonable efforts were made to avoid removal, found placement outside the home was in his best interest, and committed him to TJJD for ten years.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether evidence was sufficient to support finding that reasonable efforts were made to avoid removal from home	J.Y. contended evidence was insufficient to show reasonable efforts had been made	State and trial court pointed to probation testimony, social-history report, and psychological evaluation showing attempts and parental inability to supervise	Court held evidence was legally and factually sufficient; no abuse of discretion
Whether commitment to TJJD (rather than a less-restrictive out-of-state school) was an abuse of discretion	J.Y. argued TJJD was not the least restrictive placement and the court should have placed him in the Pennsylvania school	State argued trial court need not choose less-restrictive alternatives and made statutorily required findings supporting TJJD commitment	Court held trial court did not abuse its discretion; it need not consider alternative dispositions if statutory findings are supported

In re J.P., 136 S.W.3d 629 (Tex. 2004) (abuse-of-discretion review of juvenile disposition modifications)
In re J.D.P., 85 S.W.3d 420 (Tex. App.—Fort Worth 2002) (juvenile court discretion in disposition)
In re D.R.A., 47 S.W.3d 813 (Tex. App.—Fort Worth 2001) (broad juvenile-court discretion in modification hearings)
In re C.J.H., 79 S.W.3d 698 (Tex. App.—Fort Worth 2002) (abuse-of-discretion standard and relevance of sufficiency review)
Ford Motor Co. v. Castillo, 444 S.W.3d 616 (Tex. 2014) (standards for legal sufficiency under civil review)
Uniroyal Goodrich Tire Co. v. Martinez, 977 S.W.2d 328 (Tex. 1998) (civil sufficiency standards)
Cent. Ready Mix Concrete Co. v. Islas, 228 S.W.3d 649 (Tex. 2007) (consideration of evidence favorable to the finding)
City of Keller v. Wilson, 168 S.W.3d 802 (Tex. 2005) (standards for weighing evidence in civil sufficiency review)
Pool v. Ford Motor Co., 715 S.W.2d 629 (Tex. 1986) (factual-sufficiency standard)
Cain v. Bain, 709 S.W.2d 175 (Tex. 1986) (factual-sufficiency review principles)
Garza v. Alviar, 395 S.W.2d 821 (Tex. 1965) (setting aside a finding when evidence is contrary to weight of evidence)