15 Texas opinions name it 3 courts 1982–2026 6 in the last five years
The cases below were cited by Texas courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.
| Case | Followed | Cited |
|---|---|---|
Matter of SJMgreen2 sentences2023See In re S.J.M., 922 S.W.2d 241, 242 (Tex. App.—Houston [14th Dist.] 1996, no writ) (“Because a juvenile transfer hearing is dispositional, rather than adjudicational in nature, a juvenile court may consider hearsay reports without violating the juvenile's right of confrontation.”); L.M.C. v. State, 861 S.W.2d 541, 542 (Tex. App.—Houston [14th Dist.] 1993, no writ) (“The juvenile court determines probable cause in a nonadversary preliminary hearing. 2005See In re J.A.W., 976 S.W.2d 260, 264 (Tex.App.-San Antonio 1998, no pet.) ("Section 54.02(e) of the Family Code, which allows the court to consider written reports from probation officers, professional court employees, and professional consultants, provides an explicit exception to the hearsay rule in a transfer to criminal court proceeding.”); In re S.J.M., 922 S.W.2d 241, 242 (Tex.App.Houston [14th Dist.] 1996, no writ) ("Because a juvenile transfer hearing is dispositional, rather than adjudicational in nature, a juvenile court may consider hearsay reports without violating the juvenile’s | 4 | 4 |
In Re GBBgreen2 sentences2005See In re J.A.W., 976 S.W.2d 260, 264 (Tex.App.-San Antonio 1998, no pet.) ("Section 54.02(e) of the Family Code, which allows the court to consider written reports from probation officers, professional court employees, and professional consultants, provides an explicit exception to the hearsay rule in a transfer to criminal court proceeding.”); In re S.J.M., 922 S.W.2d 241, 242 (Tex.App.Houston [14th Dist.] 1996, no writ) ("Because a juvenile transfer hearing is dispositional, rather than adjudicational in nature, a juvenile court may consider hearsay reports without violating the juvenile’s 1996In re G.B.B., 638 S.W.2d 162, 164 (Tex.App.-Houston [1st Dist.] 1982, no writ). | 3 | 3 |
McKaine v. Stategreen2 sentences2026See, e.g., In re C.P.C., 2025 WL 2956226 , at *2 (“Because a juvenile transfer hearing is dispositional rather than adjudicational in nature, a juvenile court may consider hearsay without violating the juvenile’s right to confrontation.”); In re B.M., 2019 WL 1388561 , at *13 (“[B]ecause the transfer hearing is a nonadversary preliminary hearing, the juvenile court may rely upon hearsay as well as written and oral testimony in making its probable-cause findings.”); In re A.W., 661 S.W.3d at 554 (“[A] juvenile court in a transfer hearing is not required to resolve the admissibility of hearsay e 2026See, e.g., In re C.P.C., 2025 WL 2956226 , at *2 (“Because a juvenile transfer hearing is dispositional rather than adjudicational in nature, a juvenile court may consider hearsay without violating the juvenile’s right to confrontation.”); In re B.M., 2019 WL 1388561 , at *13 (“[B]ecause the transfer hearing is a nonadversary preliminary hearing, the juvenile court may rely upon hearsay as well as written and oral testimony in making its probable-cause findings.”); In re A.W., 661 S.W.3d at 554 (“[A] juvenile court in a transfer hearing is not required to resolve the admissibility of hearsay e | 2 | 2 |
Grant v. Stategreen2 sentences2026See, e.g., In re C.P.C., 2025 WL 2956226 , at *2 (“Because a juvenile transfer hearing is dispositional rather than adjudicational in nature, a juvenile court may consider hearsay without violating the juvenile’s right to confrontation.”); In re B.M., 2019 WL 1388561 , at *13 (“[B]ecause the transfer hearing is a nonadversary preliminary hearing, the juvenile court may rely upon hearsay as well as written and oral testimony in making its probable-cause findings.”); In re A.W., 661 S.W.3d at 554 (“[A] juvenile court in a transfer hearing is not required to resolve the admissibility of hearsay e 2026See, e.g., In re C.P.C., 2025 WL 2956226 , at *2 (“Because a juvenile transfer hearing is dispositional rather than adjudicational in nature, a juvenile court may consider hearsay without violating the juvenile’s right to confrontation.”); In re B.M., 2019 WL 1388561 , at *13 (“[B]ecause the transfer hearing is a nonadversary preliminary hearing, the juvenile court may rely upon hearsay as well as written and oral testimony in making its probable-cause findings.”); In re A.W., 661 S.W.3d at 554 (“[A] juvenile court in a transfer hearing is not required to resolve the admissibility of hearsay e | 2 | 2 |
In Re CDTgreen2 sentences2020See In re C.E.C., No. 2-06-065-CV, 2006 WL 3627134 , at *2 (Tex. App.—Fort Worth Dec. 14, 2006, no pet.) (mem. op.); In re C.D.T., 98 S.W.3d 280, 283 (Tex. App.— Houston [1st Dist.] 2003, pet. denied); In re R. 2006Dr. Cooke saw C.E.C. three times for a total of about four hours and administered several tests. 13: In re C.D.T., 98 S.W.3d 280, 283 (Tex. App.—Houston [1st Dist.] 2003, pet. denied); see In re S.M., No. 02-05-00262-CV, 2006 WL 2986613, at *2-3 (Tex. App.—Fort Worth Oct. 19, 2006, no pet. h.) (holding that Crawford v. Washington, 541 U.S. 36 , 124 S. Ct. 1354 (2004) does not apply to a juvenile transfer hearing because a transfer hearing is not a stage of a criminal prosecution for Sixth Amendment purposes); In re D.J., 909 S.W.2d 621, 623 (Tex. App.—Fort Worth 1995, writ dism’d w.o.j.) (“A s | 2 | 2 |
Crawford v. Washingtongreen2 sentences2006Dr. Cooke saw C.E.C. three times for a total of about four hours and administered several tests. 13: In re C.D.T., 98 S.W.3d 280, 283 (Tex. App.—Houston [1st Dist.] 2003, pet. denied); see In re S.M., No. 02-05-00262-CV, 2006 WL 2986613, at *2-3 (Tex. App.—Fort Worth Oct. 19, 2006, no pet. h.) (holding that Crawford v. Washington, 541 U.S. 36 , 124 S. Ct. 1354 (2004) does not apply to a juvenile transfer hearing because a transfer hearing is not a stage of a criminal prosecution for Sixth Amendment purposes); In re D.J., 909 S.W.2d 621, 623 (Tex. App.—Fort Worth 1995, writ dism’d w.o.j.) (“A s 2006Dr. Cooke saw C.E.C. three times for a total of about four hours and administered several tests. 13: In re C.D.T., 98 S.W.3d 280, 283 (Tex. App.—Houston [1st Dist.] 2003, pet. denied); see In re S.M., No. 02-05-00262-CV, 2006 WL 2986613, at *2-3 (Tex. App.—Fort Worth Oct. 19, 2006, no pet. h.) (holding that Crawford v. Washington, 541 U.S. 36 , 124 S. Ct. 1354 (2004) does not apply to a juvenile transfer hearing because a transfer hearing is not a stage of a criminal prosecution for Sixth Amendment purposes); In re D.J., 909 S.W.2d 621, 623 (Tex. App.—Fort Worth 1995, writ dism’d w.o.j.) (“A s | 1 | 2 |
LMC v. Stategreen1 sentence2023See In re S.J.M., 922 S.W.2d 241, 242 (Tex. App.—Houston [14th Dist.] 1996, no writ) (“Because a juvenile transfer hearing is dispositional, rather than adjudicational in nature, a juvenile court may consider hearsay reports without violating the juvenile's right of confrontation.”); L.M.C. v. State, 861 S.W.2d 541, 542 (Tex. App.—Houston [14th Dist.] 1993, no writ) (“The juvenile court determines probable cause in a nonadversary preliminary hearing. | 1 | 1 |
Russeau v. Stategreen1 sentence2006Crawford, 541 U.S. at 36 , 124 S.Ct. at 1354 ; Russeau v. State, 171 S.W.3d 871, 880 (Tex.Crim.App.2005), cert. denied, ___ U.S. ___, 126 S.Ct. 2982 , 165 L.Ed.2d 989 (2006). *426 Section 54.11(d) purports to allow probation officer reports, incident reports, and the like to come in at a juvenile transfer hearing without the testimony of the authoring witness, thereby denying a juvenile's confrontation right to cross-examine witnesses against him. | 1 | 1 |
In Re SMgreen1 sentence2006Dr. Cooke saw C.E.C. three times for a total of about four hours and administered several tests. 13: In re C.D.T., 98 S.W.3d 280, 283 (Tex. App.—Houston [1st Dist.] 2003, pet. denied); see In re S.M., No. 02-05-00262-CV, 2006 WL 2986613, at *2-3 (Tex. App.—Fort Worth Oct. 19, 2006, no pet. h.) (holding that Crawford v. Washington, 541 U.S. 36 , 124 S. Ct. 1354 (2004) does not apply to a juvenile transfer hearing because a transfer hearing is not a stage of a criminal prosecution for Sixth Amendment purposes); In re D.J., 909 S.W.2d 621, 623 (Tex. App.—Fort Worth 1995, writ dism’d w.o.j.) (“A s | 1 | 1 |
In re D.J.green1 sentence2006Dr. Cooke saw C.E.C. three times for a total of about four hours and administered several tests. 13: In re C.D.T., 98 S.W.3d 280, 283 (Tex. App.—Houston [1st Dist.] 2003, pet. denied); see In re S.M., No. 02-05-00262-CV, 2006 WL 2986613, at *2-3 (Tex. App.—Fort Worth Oct. 19, 2006, no pet. h.) (holding that Crawford v. Washington, 541 U.S. 36 , 124 S. Ct. 1354 (2004) does not apply to a juvenile transfer hearing because a transfer hearing is not a stage of a criminal prosecution for Sixth Amendment purposes); In re D.J., 909 S.W.2d 621, 623 (Tex. App.—Fort Worth 1995, writ dism’d w.o.j.) (“A s | 1 | 1 |
Matter of DSgreen1 sentence2006Code Ann. § 54.11(d); see In re D.S. , 921 S.W.2d 383, 388 (Tex. App.—Corpus Christi 1996, writ dism’d w.o.j.) (holding that family code section 54.11(d) authorizes the use of TYC reports); accord C.D.T., 98 S.W.3d at 282-83 . | 1 | 1 |
In Re RGSgreen1 sentence2005See In re J.A.W., 976 S.W.2d 260, 264 (Tex.App.-San Antonio 1998, no pet.) ("Section 54.02(e) of the Family Code, which allows the court to consider written reports from probation officers, professional court employees, and professional consultants, provides an explicit exception to the hearsay rule in a transfer to criminal court proceeding.”); In re S.J.M., 922 S.W.2d 241, 242 (Tex.App.Houston [14th Dist.] 1996, no writ) ("Because a juvenile transfer hearing is dispositional, rather than adjudicational in nature, a juvenile court may consider hearsay reports without violating the juvenile’s | 1 | 1 |
In Re QDgreen1 sentence2005See In re J.A.W., 976 S.W.2d 260, 264 (Tex.App.-San Antonio 1998, no pet.) ("Section 54.02(e) of the Family Code, which allows the court to consider written reports from probation officers, professional court employees, and professional consultants, provides an explicit exception to the hearsay rule in a transfer to criminal court proceeding.”); In re S.J.M., 922 S.W.2d 241, 242 (Tex.App.Houston [14th Dist.] 1996, no writ) ("Because a juvenile transfer hearing is dispositional, rather than adjudicational in nature, a juvenile court may consider hearsay reports without violating the juvenile’s | 1 | 1 |
Matter of Jawgreen1 sentence2005See In re J.A.W., 976 S.W.2d 260, 264 (Tex.App.-San Antonio 1998, no pet.) ("Section 54.02(e) of the Family Code, which allows the court to consider written reports from probation officers, professional court employees, and professional consultants, provides an explicit exception to the hearsay rule in a transfer to criminal court proceeding.”); In re S.J.M., 922 S.W.2d 241, 242 (Tex.App.Houston [14th Dist.] 1996, no writ) ("Because a juvenile transfer hearing is dispositional, rather than adjudicational in nature, a juvenile court may consider hearsay reports without violating the juvenile’s | 1 | 1 |
United States v. A.R., a Male Juvenile, A.R.green2 sentences1999Appellant is challenging the use of the report against him at the juvenile transfer hearing. [12] A similar argument was made in United States v. A.R., 38 F.3d 699 (3 rd Cir.1994). 1999Appellant is challenging the use of the report against him at the juvenile transfer hearing. 12 A similar argument was made in United States v. AR, 38 F.3d 699 (3rd Cir.1994). | 1 | 1 |
Matter of MILgreen2 sentences1994The State must only "present to the court evidence that will permit the court to exercise its discretion...." Matter of M.I.L., 601 S.W.2d at 177 . 1994The State must only “present to the court evidence that will permit the court to exercise its discretion....” Matter of M.I.L., 601 S.W.2d at 177. | 1 | 1 |
Geesa v. Statered2 sentences1994Compare, Geesa v. State, 820 S.W.2d 154 (Tex.Cr.App. 1991). 1994Compare, Geesa v. State, 820 S.W.2d 154 (Tex.Cr.App.1991). | 1 | 1 |
BRD v. Stategreen2 sentences1994In the Matter of Honsaker, 539 S.W.2d 198 (Tex.App. Dallas 1976); and, B.R.D. v. State, 575 S.W.2d 126 (Tex.App.Corpus Christi 1979). 1994Honsaker, 539 S.W.2d at 201 ; and, B.R.D., 575 S.W.2d at 131. | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Texas. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
In re D.W.L.
green
1 sentence2023The juvenile court may use hearsay as well as written and oral testimony.”) (internal citations omitted); In re D.W.L., 828 S.W.2d 520 , 524–25 (Tex. App.—Houston [14th Dist.] 1992, no writ) (“Further, the trial court can determine probable cause in a nonadversary preliminary hearing through the use of hearsay besides written and oral testimony. | 1 | 2023–2023 |
Kent v. United States
green
2 sentences2021The Supreme Court has recognized the waiver of the juvenile court’s jurisdiction as a “critically important” action and held that the transfer “hearing must measure up to the essentials of due process and fair treatment.” Kent v. United States, 383 U.S. 541, 562 , 86 S. Ct. 1045, 1057 , 16 L. 2021The Supreme Court has recognized the waiver of the juvenile court’s jurisdiction as a “critically important” action and held that the transfer “hearing must measure up to the essentials of due process and fair treatment.” Kent v. United States, 383 U.S. 541, 562 , 86 S. Ct. 1045, 1057 , 16 L. | 1 | 2021–2021 |
cluster 250010
green
1 sentence2021Indeed, Kent goes on to explain that due process in a juvenile transfer hearing mandates “a hearing, including access to the social records and probation or similar reports which presumably are considered by the court, and . . . a statement of reasons for the Juvenile Court’s decision.” Id. at 557 . | 1 | 2021–2021 |
Sorto v. Texas
green
1 sentence2006Crawford, 541 U.S. at 36 , 124 S.Ct. at 1354 ; Russeau v. State, 171 S.W.3d 871, 880 (Tex.Crim.App.2005), cert. denied, ___ U.S. ___, 126 S.Ct. 2982 , 165 L.Ed.2d 989 (2006). *426 Section 54.11(d) purports to allow probation officer reports, incident reports, and the like to come in at a juvenile transfer hearing without the testimony of the authoring witness, thereby denying a juvenile's confrontation right to cross-examine witnesses against him. | 1 | 2006–2006 |
Matter of Honsaker
green
2 sentences1994In the Matter of Honsaker, 539 S.W.2d 198 (Tex.App. Dallas 1976); and, B.R.D. v. State, 575 S.W.2d 126 (Tex.App.Corpus Christi 1979). 1994Honsaker, 539 S.W.2d at 201 ; and, B.R.D., 575 S.W.2d at 131. | 1 | 1994–1994 |
Coffin v. State
green
2 sentences1994Coffin v. State, 850 S.W.2d 608 (Tex.App. El Paso 1993). 1994Coffin v. State, 850 S.W.2d 608 (Tex.App.— El Paso 1993). | 1 | 1994–1994 |
Matter of JRC
green
1 sentence1982In the Matter of J.R.C., supra. By his failure to do so, he waived his right to confrontation and cross-examination. *164 Appellant's argument, concerning the hearsay nature of the reports and the denial of the right to confront the absent witnesses has no merit when directed at a juvenile transfer hearing. | 1 | 1982–1982 |
Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.
Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.