In re P.C.

Summary

The Texas Court of Appeals held that statements and conduct by a juvenile occurring after a magistrate ordered the juvenile detained were not made "at the detention hearing" within the meaning of Texas Family Code section 54.01(g). The court therefore upheld the admission of the juvenile's threats and related conduct at the disposition hearing and affirmed the trial court's judgment. The opinion was issued as a memorandum opinion.

Holdings

1. A detention hearing ends when the magistrate orders the juvenile detained; statements made afterward are not statements made 'at the detention hearing' within the meaning of section 54.01(g).
2. The trial court did not abuse its discretion by admitting P.C.'s threats and, to the extent challenged, the hallway head-butting attempt and spitting incident, because all occurred after the detention hearing had ended.

Questions Presented

1. Whether Texas Family Code section 54.01(g), which prohibits admission at another hearing of a child's statement made at a detention hearing, barred admission at P.C.'s disposition hearing of statements made after the magistrate ordered P.C. detained.
2. Whether the trial court abused its discretion by admitting P.C.'s threats and related conduct at the disposition hearing.

Disposition

affirmed