in the Matter of J. F. C., 01-17-00411-CV

A juvenile, John Francis Conner (pseudonym), was alleged to have kidnapped, sexually assaulted, and murdered 15‑year‑old Kristen Price; her body was found hidden in an apartment unit.
Evidence recovered from John’s phone included threatening texts demanding Kristen skip school and a recording that captured audio of a sexual assault; John later admitted to killing her during a detective interview.
The State filed a motion to waive juvenile court jurisdiction under Tex. Fam. Code §54.02 and transfer John to criminal district court to be tried as an adult for capital murder.
At the transfer hearing the juvenile court heard testimony from the investigating detective and a psychologist and considered documentary evidence (phone texts, video/audio, psychological report, disciplinary and delinquency history).
The juvenile court found probable cause, that John was at least 14 at the time of the alleged offense, and that the Section 54.02(f) factors (offense against a person; child’s maturity; child’s record; public protection/rehabilitation prospects) favored transfer.
John appealed, arguing the evidence was legally and factually insufficient to support waiver; the court of appeals affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether evidence is legally and factually sufficient to support juvenile court’s waiver/transfer under Tex. Fam. Code §54.02	Conner: evidence insufficient to show the seriousness/background require criminal proceedings; court should have weighed his low IQ and rehabilitation prospects more heavily	State: documentary evidence, confession, phone texts/video, psychologist’s report, and delinquency history support the four §54.02(f) factors and transfer	Affirmed: appellate court held the juvenile court’s findings were legally and factually sufficient and its waiver decision was not an abuse of discretion

Moon v. State, 451 S.W.3d 28 (Tex. Crim. App. 2014) (sets standards for reviewing juvenile waiver orders and requires written findings applying §54.02(f) factors)
Moon v. State, 410 S.W.3d 366 (Tex. App.—Houston [1st Dist.] 2013) (explains sufficiency review approach for transfer findings)