Mary Kuol v. State, 14-14-01008-CR

Appellant Mary Kuol was charged with felony prostitution and was enhanced by five prior prostitution convictions from Dallas County.
The five prior convictions allegedly were entered while Kuol was a juvenile, raising jurisdiction questions.
Kuol pled true to the current felony charge and was deferred adjudication, later adjudicated guilty and sentenced to three years.
Kuol moved to arrest judgment and for a new trial asserting lack of jurisdiction on the enhancement judgments.
The State conceded Kuol may have been a juvenile at the time, but the record did not reveal whose name and birth date appeared on the prior judgments.
The Court held that the record left questions about the enhancement judgments, but ultimately upheld the current conviction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the enhancement judgments are void for lack of jurisdiction	Kuol	State	No void judgments; record leaves questions but not void
Whether legislative changes prevent gaming the system by misrepresenting age	Kuol	State	Convictions upheld; cannot prevail under current law

Bannister v. State, 552 S.W.2d 124 (Tex. Crim. App. 1977) (misrepresentation to evade juvenile jurisdiction; game of courts described)
Ex parte Waggoner, 61 S.W.3d 429 (Tex. Crim. App. 2001) (legislative response to Bannister; article 4.18 discussed)
In re B.W., 313 S.W.3d 818 (Tex. 2010) (juvenile waiver doctrines)
In re E.D.C., 88 S.W.3d 789 (Tex. App.—El Paso 2002) (waiver/juvenile jurisdiction implications)
Kendall v. Kendall, 340 S.W.3d 483 (Tex. App.—Houston [1st Dist.] 2011) (collateral attack standard and void judgments)
Nix v. State, 65 S.W.3d 664 (Tex. Crim. App. 2001) (void judgment standard; complete lack of power to render judgment)
Light v. State, 993 S.W.2d 740 (Tex. App.—Austin 1999) (juvenile waiver issues; discussed in context of Bannister and Waggoner)