in the Matter of J.W., a Juvenile, 12-17-00016-CV

J.W., a juvenile, judicially confessed to burglary (entering a habitation with intent to commit theft) and was adjudicated delinquent and placed on probation.
Over multiple successive terms, J.W. repeatedly violated probation; he signed stipulations confessing each violation and the court extended probation and ordered various placements and programs (Unlimited Visions, Intensive Supervision, Drug Court, Grayson County placement).
While at Grayson County, J.W. initially performed adequately but then accumulated numerous disciplinary write-ups, confinement reports, and was unsuccessfully discharged for persistent rule violations and low program points.
The trial court found by preponderance that J.W. (1) violated a lawful court order, (2) continued to need supervision and rehabilitation, (3) could not receive necessary care/supervision in his home, and (4) it was in his best interest to be placed outside the home.
The court committed J.W. to the Texas Juvenile Justice Department (TJJD) for an indeterminate term not to exceed his nineteenth birthday. J.W. appealed, raising four issues.

Issue	Plaintiff's Argument (J.W.)	Defendant's Argument (State)	Held
1. Trial court made required findings for TJJD commitment	Trial court failed to make the specific findings required by Tex. Fam. Code §54.05(m)(1)	Trial court made the statutory findings (even if via checked boxes) and supplemented them in the record	Court held findings were made and sufficient; issue overruled
2. Least restrictive alternative / abuse of discretion	Court abused discretion by not evaluating or choosing a less restrictive placement before committing to TJJD	Court had broad discretion; J.W. had multiple failed rehabilitative attempts and no suitable alternative existed	Court held commitment reasonable; no abuse of discretion; issue overruled
3. Constitutionality of §54.05(j) as-applied (due process)	Section 54.05(j) is unconstitutional as applied to J.W.	Constitutional challenge was not raised in trial court and is therefore waived	Court held issue unpreserved and overruled on appeal
4. Legal sufficiency of evidence supporting commitment	Evidence was insufficient; J.W. offered explanations for violations and State’s proof was scant regarding Grayson County conduct	Record contained stipulation of violation, disciplinary reports, confinement reports, and poor program performance supporting violation and need for commitment	Court held evidence legally sufficient to support violation finding and commitment; issue overruled

In the Matter of C.J.B., 463 S.W.3d 626 (Tex. App.—El Paso 2015) (two-step review for juvenile modification and commitment under §54.05)
In re M.A.S., 438 S.W.3d 803 (Tex. App.—El Paso 2014) (juvenile courts may decline repeated leniency; commitment discretion)
In re J.M., 287 S.W.3d 481 (Tex. App.—Texarkana 2009) (statutory language plus supplemental findings satisfy §54.05(m)(1) requirements)
Rodriguez v. State, 93 S.W.3d 60 (Tex. Crim. App. 2002) (presumption of statute validity and burden on challenger)
Reynolds v. State, 423 S.W.3d 377 (Tex. Crim. App. 2014) (as-applied constitutional claims must be preserved at trial)