## Facts

- Cameron Moon was 16 years old when Christopher Seabrook was fatally shot during an attempted marijuana transaction in a grocery-store parking lot.
- A witness reported that Seabrook approached a vehicle, an argument occurred, and a white male exited and fired multiple shots as Seabrook fled.
- Investigation connected Moon to the offense through phone records, witness identification, and text messages indicating a planned robbery and post-shooting instructions to conceal identity.
- Moon was initially charged in juvenile court and the State sought waiver of juvenile jurisdiction (certification) to prosecute him as an adult.
- At the waiver hearing, a forensic psychiatrist testified Moon lacked sophistication and maturity, did not show a tendency toward violence, and was amenable to rehabilitation in the juvenile system.
- The juvenile court nonetheless issued a waiver/transfer order with findings tracking statutory factors, including that Moon was sufficiently mature and that juvenile-system rehabilitation and public-protection prospects were poor.
- Moon was tried as an adult in district court, convicted of murder, and sentenced to 30 years’ imprisonment.
- On appeal, Moon challenged the validity of the juvenile transfer and also argued the district court erred by denying his motion to suppress custodial statements.

## Issues

1. Whether the juvenile court’s order waiving jurisdiction and transferring Moon to adult criminal court satisfied Texas statutory requirements and was supported by factually sufficient evidence.
2. Whether the district court erred in denying Moon’s motion to suppress his custodial statements.

## Decision

- The court of appeals vacated the district court’s judgment of conviction and dismissed the case for lack of criminal-court jurisdiction.
- The court held the juvenile court’s waiver/transfer order was legally defective because its essential findings were not supported by factually sufficient evidence.
- Because a valid juvenile transfer is a jurisdictional prerequisite to adult prosecution, the district court never acquired jurisdiction.
- The court did not reach the suppression issue after resolving the case on the transfer/jurisdiction ground.

## Legal Principles

- A juvenile court may waive jurisdiction and transfer a child for adult prosecution only after considering statutory factors and making specific, reviewable findings on those factors.
- A transfer order that merely recites statutory language, without an evidence-based explanation supporting the required findings, is inadequate for meaningful appellate review.
- The seriousness of the charged offense, by itself, cannot supply the evidentiary basis for waiver where the statute requires a multi-factor, individualized determination.
- An invalid waiver of juvenile jurisdiction deprives the criminal district court of jurisdiction, requiring vacatur of any resulting conviction.

## Conclusion

The court of appeals set aside Moon’s adult murder conviction because the juvenile court’s transfer decision lacked factually supported findings on required statutory factors; without a valid transfer order, the criminal district court had no jurisdiction to prosecute him as an adult.


Moon v. State, 410 S.W.3d 366 (Tex. App.—Houston [1st Dist.] 2013)