Ex parte Miguel Angel Navarro (original by judge hervey)Annotate this Case
In Moon v. Texas, 451 S.W.3d 28 (Tex. Crim. App. 2014), the Court of Criminal Appeals agreed with the court of appeals that a juvenile court’s transfer order waiving its exclusive jurisdiction is subject to legal and factual-sufficiency appellate review. The issues in this case were whether "Moon" was retroactive, and if so, whether the transfer order in this case was legally and factually insufficient. Applicant Miguel Navarro was fifteen years old when he was charged with murder and two counts of aggravated assault. When the party got too large, the host told a group of people, including Navarro, to leave because he did not know them. An altercation ensued during which three people were stabbed, including the host, who died at the scene. Navarro fled in a car with his friends and returned to his home later that night. The next morning, detectives showed up at Navarro’s home after they were told that he may have stabbed the people at the party. Navarro was eventually taken into custody. The Court did not reach the question of "Moon" because Navarro failed to show that his subsequent writ applications satisfy the Article 11.07 Section 4 subsequent-writ bar of the Texas Code of Criminal Procedure. As a result, the Court dismissed his writ applications.