FORT WORTH, Texas (CN) - After she gave a lenient sentence to the drunken driver who blamed his fatal crash on "affluenza," a Texas judge wrongfully shut the media out of another minor's capital murder case, an appeals court ruled Tuesday.
R.J.D., as the defendant is described in the Tuesday ruling, had been in jail "an unusually long time" before his January 2014 adult-certification hearing before state District Judge Jean Boyd because medical conditions made his attorney unavailable, according to the ruling.
Aside from mentioning that R.J.D. had a sexual relationship with his victim, the ruling makes no other mention of the capital murder case. R.J.D. turned 17 in December 2013.
Boyd said she closed her courtroom to the media and public for that hearing because a determinate sentence trial was scheduled for Jan. 22 and she did not want to taint the jury pool. Prosecutors opposed the order and the defendant did not request it.
R.J.D. ultimately reached a plea agreement after Boyd declined to certify him as an adult. Boyd closed the courtroom at the determinate sentence trial as well. Again, prosecutors opposed the closure and the defendant did not ask for it.
Several media outlets - including the Dallas Morning News, Fort Worth Star-Telegram, NBC-affiliate KXAS, ABC-affiliate WFAA, Fox-affiliate KDFW and CBS-affiliate KTVT - asked Boyd to vacate her closure orders and make transcripts of the hearings available. Boyd denied the motions on March 20.
In reversing that ruling Tuesday, a three-judge panel with the 2nd District Court of Appeals in Fort Worth said Boyd abused her discretion.
The Texas Family Code requires some evidence that supports a good-cause finding that the public should be excluded, the court found.
"In the absence of evidence in the record - stipulated facts, judicial notice taken of facts or of files, testimony, self-authenticating documents, or some other evidence - as to why and how R.J.D.'s jury pool might be tainted by the media's and the public's presence at the January 10 hearing, good cause has not been 'shown' for respondent's January 10 courtroom closure order as required by the plain language of the statute," Justice Sue Walker wrote for the court.
Boyd's reasons to close the second hearing - that prosecutors had supposedly removed facts from the stipulation of evidence to be presented, causing concern over the publication of the omitted facts - also failed to sway the appellate panel.
"We recognize that the goals of the juvenile justice system are different from the adult criminal justice system; otherwise, a separate juvenile justice system would be unnecessary," the 26-page opinion states. "The different goals of the juvenile justice system cause the types of privacy concerns at issue here to be more compelling in juvenile cases. And we do not doubt that privacy concerns could, in some instances, justify closing a juvenile proceeding involving a juvenile who is at least fourteen years old for some period if the statutory requisite of good cause is shown on the record. But, again, as set forth above, giving the language of family code section 54.08(a) its plain meaning, in the absence of evidence in the record - stipulated facts, judicial notice taken of facts or of files, testimony, self-authenticating documents, or some other evidence - as to why and how and the extent to which the public dissemination of these private facts would be detrimental to the juvenile or to another party, good cause has not been shown for respondent's January 22 courtroom closure order as required by the plain language of the statute."
The appeals court declined the media's request to define "good cause shown," however, and it would not provide procedures for future courtroom closures in other cases.
"We lack the jurisdiction to do so," Walker wrote. "The Texas Constitution's separation of powers provision prohibits courts from issuing advisory opinions that decide abstract questions of law."
Judge Boyd made headlines in December 2013 for sentencing another 17-year-old, Ethan Couch
, to 10 years probation and therapy after he drunkenly crashed a truck in south Fort Worth, killing four.
During trial, defense psychologist Dr. G. Dick Miller testified that Couch was the product of "affluenza," where his family allegedly felt wealth bought privilege and that there was no rational link between behavior and consequences. Miller said Couch's parents gave him "freedoms no young person should have."
Boyd told Couch at sentencing that he is responsible for the deaths but that she believed he would not receive the therapy he needs in jail.
Boyd's office did not immediately respond to a request for comment Wednesday.