What Texas Penal Code sections apply to juvenile robbery charges?
This question has been addressed in 2 Texas court opinions:
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.”
In the matter of J.C., a juvenile
COA04 — February 4, 2026
A juvenile, J.C., appealed his adjudication for aggravated robbery and assault, arguing that the appellate court should apply a 'factual sufficiency' standard of review to his case—a standard used in certain civil matters that allows the court to weigh evidence. The Fourth Court of Appeals rejected this argument, reaffirming that juvenile delinquency proceedings are 'quasi-criminal' and subject only to the strict 'legal sufficiency' standard used in adult criminal cases. The court held that as long as any rational jury could have found the defendant guilty based on the evidence viewed in favor of the verdict (such as the victim's identification and fingerprint evidence found in this case), the adjudication must be upheld.
Litigation Takeaway
“Appealing a juvenile delinquency verdict is significantly harder than appealing a standard family law order because courts will not re-weigh the evidence. Because these cases follow criminal appellate standards, you cannot win by simply arguing the jury made the wrong choice between conflicting stories; you must prove that there was legally 'no evidence' to support the conviction.”