Isaac Nathaniel Rodriguez v. State
2015 Tex. App. LEXIS 9668
| Tex. App. | 2015Background
- Rodriguez, a juvenile, was charged with murder and waived to criminal court after a State petition.
- Suppression of evidence was denied; Rodriguez pleaded guilty and received 30 years’ confinement plus a $1,000 fine.
- Juvenile court found probable cause and that the 54.02(a)(3) factors favored transfer to criminal court.
- Rodriguez refused a psychological evaluation; other studies were completed prior to the transfer decision.
- The court made case-specific 54.02(f) findings, including offense against a person, Rodriguez’s sophistication, and rehabilitation concerns.
- Appellate review affirmed the transfer, holding the 54.02 factors supported the transfer and that the order was specific and adequate.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was there factually insufficient evidence to transfer? | Rodriguez argues insufficient evidence. | State contends evidence supports transfer. | Transfer affirmed; evidence sufficient. |
Key Cases Cited
- Moon v. State, 451 S.W.3d 28 (Tex. Crim. App. 2014) (two-step inquiry: sufficiency and application of discretion; 54.02 factors must be considered)
- Faisst v. State, 105 S.W.3d 8 (Tex. App.—Tyler 2003) (seriousness and public welfare justify transfer; 54.02 factors relevant)
- In re M.A., 935 S.W.2d 891 (Tex. App.—San Antonio 1996) (seriousness can override lack of prior juvenile history)
- Bleys v. State, 319 S.W.3d 857 (Tex. App.—San Antonio 2010) (recognizes consideration of 54.02(f) factors; later abrogated by Moon)