nonadversary preliminary hearing (Texas) · Go Syfert
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nonadversary preliminary hearing in Texas

11 Texas opinions name it 2 courts 1993–2026 4 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.

Followed or applied (7)

CaseFollowedCited
LMC v. Stategreen
texapp · 1993 · cited in 5 Texas opinions naming this issue, 1996–2023
2 sentences

2023See 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.

2023Court noted that “because 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.” Id. (citing Navarro v. State, No. 01-11-00139-CR, 2012 WL 3776372 , at *5 (Tex. App.—Houston [1st Dist.] Aug. 30, 2012 pet. ref’d) (mem. op., not designated for publication); see also L.M.C. v. State, 861 S.W.2d 541, 542 (Tex. App.—Houston [14th Dist.] 1993, no pet.) (stating transfer hearing is “nonadversary preliminary hearing” and “appellant’s rights will be fully protected when the case r

35
McKaine v. Stategreen
texapp · 2005 · cited in 3 Texas opinions naming this issue, 2023–2026
2 sentences

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

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

33
Grant v. Stategreen
texapp · 2010 · cited in 3 Texas opinions naming this issue, 2023–2026
2 sentences

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

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

33
In re D.W.L.green
texapp · 1992 · cited in 5 Texas opinions naming this issue, 1993–2023
2 sentences

2023The 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.

2023The 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.

25
In Re GBBgreen
texapp · 1982 · cited in 1 Texas opinions naming this issue, 2023–2023
1 sentence

2023See Grant v. State, 313 S.W.3d 443, 444 (Tex. App.—Waco 2010, no pet.) (“[A] juvenile court can determine probable cause in a nonadversary preliminary hearing through the use of hearsay besides written and oral testimony.”); McKaine v. State, 170 S.W.3d 285, 289 (Tex. App.—Corpus Christi–Edinburg 2005, no pet.) (concluding that juvenile court may consider hearsay evidence because “[s]trict rules of evidence are not applied in transfer proceedings.”); 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

11
Matter of Jawgreen
texapp · 1998 · cited in 1 Texas opinions naming this issue, 2023–2023
1 sentence

2023See Grant v. State, 313 S.W.3d 443, 444 (Tex. App.—Waco 2010, no pet.) (“[A] juvenile court can determine probable cause in a nonadversary preliminary hearing through the use of hearsay besides written and oral testimony.”); McKaine v. State, 170 S.W.3d 285, 289 (Tex. App.—Corpus Christi–Edinburg 2005, no pet.) (concluding that juvenile court may consider hearsay evidence because “[s]trict rules of evidence are not applied in transfer proceedings.”); 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

11
Matter of SJMgreen
texapp · 1996 · cited in 1 Texas opinions naming this issue, 2023–2023
2 sentences

2023See 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.

2023See 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.

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Texas. Read the followed side critically anyway.

Statutes the citing opinions construe

TX § Tex. Fam. Code § 54.02 (11) TX § Tex. Fam. Code § 51.09 (4) TX § Tex. Penal Code § 19.02 (4) TX § Tex. Penal Code § 7.02 (4) TX § Tex. Fam. Code § 51.02 (3)

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.

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