Rodriguez, Isaac Nathaniel
PD-1365-15
| Tex. App. | Dec 18, 2015Background
- At 16, Isaac N. Rodriguez was arrested after admitting at the scene and to an officer that he "did it" in the beating/stabbing death of Adriana Terry; police found a bloody baseball bat and knife blade.
- The State filed a juvenile petition seeking discretionary transfer/waiver to criminal court; the juvenile court held a contested certification hearing and ordered transfer.
- Pre-transfer evaluations were ordered; Rodriguez refused to participate in the psychological exam but probation and staffing reports were completed.
- Rodriguez was later indicted in adult court, moved to suppress, pleaded guilty to murder under a plea bargain, and received 30 years' imprisonment.
- On direct appeal Rodriguez argued the juvenile transfer order was boilerplate and insufficient under Moon v. State; the Fourth Court of Appeals affirmed the transfer order as sufficiently case-specific.
Issues
| Issue | Plaintiff's Argument (Rodriguez) | Defendant's Argument (State) | Held |
|---|---|---|---|
| Sufficiency of juvenile transfer order under Moon v. State | The juvenile court's waiver/order used generic boilerplate and did not include case‑specific factual findings required by Moon, so appellate review cannot fairly assess whether §54.02(f) factors were applied. | The transfer order, read with the record and the probation/diagnostic reports, contains specific findings and the record supports each §54.02(f) factor; transfer was appropriate. | The Fourth Court of Appeals held the juvenile court's order and the record were factually and legally sufficient; affirmed transfer and conviction. |
Key Cases Cited
- Moon v. State, 451 S.W.3d 28 (Tex. Crim. App. 2014) (appellate review requires juvenile court to state case‑specific findings for §54.02(f) factors and appellate courts must measure sufficiency against the juvenile court's stated findings)
- Bleys v. State, 319 S.W.3d 857 (Tex. App.—San Antonio 2010) (discusses confession and transfer factors; precedes Moon)
- Faisst v. State, 105 S.W.3d 7 (Tex. App.—Tyler 2003) (explains §54.02(a)(3) burden and that seriousness of offense can alone support transfer)