What happens when a juvenile is sentenced for aggravated robbery?
This question has been addressed in 2 Texas court opinions:
In the Matter of F.M., A Juvenile
COA12 — February 18, 2026
A juvenile, F.M., appealed a trial court order transferring him from the Texas Juvenile Justice Department (TJJD) to the Texas Department of Criminal Justice (TDCJ) to serve the remainder of an 18-year sentence for aggravated robbery. The Twelfth Court of Appeals reviewed the juvenile's behavioral record—which included 71 incidents and a failure to complete violent offender treatment—and determined the trial court did not abuse its discretion in ordering the transfer. Crucially, the court also addressed whether appointed counsel could withdraw after filing an Anders brief (a brief stating the appeal is frivolous). Drawing a parallel to parental termination cases under In re P.M., the court held that the statutory right to counsel in juvenile proceedings extends through the filing of a petition for review in the Texas Supreme Court. Consequently, the court affirmed the transfer but denied the attorney's motion to withdraw.
Litigation Takeaway
“In cases involving appointed counsel under the Texas Family Code (including juvenile and termination matters), an Anders brief is not an immediate exit strategy. Counsel's duty of representation is "sticky" and persists through the petition for review stage in the Texas Supreme Court; you must remain appointed to assist the client with further review if they request it, even if you believe the appeal lacks merit.”
Jarven Roberson v. The State of Texas
COA07 — January 27, 2026
Appellant Jarven Roberson appealed the trial court's decision to adjudicate his guilt for third-degree felony assault family violence involving strangulation after he violated the terms of his deferred adjudication community supervision. The Seventh Court of Appeals conducted an independent review of the record under the Anders standard to determine if any non-frivolous grounds for appeal existed. The court found that because Roberson admitted to violations and the eight-year sentence was within the legal statutory range, there was no reversible error. Consequently, the appellate court affirmed the trial court’s judgment and granted appointed counsel’s motion to withdraw.
Litigation Takeaway
“The shift from deferred adjudication to a final felony conviction for domestic violence is a critical turning point in custody litigation. A final judgment of guilt for strangulation triggers mandatory statutory presumptions against joint managing conservatorship under Texas Family Code § 153.004 and may provide grounds for the termination of parental rights if the resulting incarceration exceeds two years.”