Using Juvenile Adjudications to Enhance Felonies

To enhance the punishment range for felony offenses, a defendant must have prior convictions. See generally Tex. Penal Code Ann. § 12.42 (Vernon Supp. 2006). Generally, juvenile adjudications are not prior convictions. Tex. Fam. Code Ann. § 51.13(a) (Vernon 2002). But for purposes of enhancement, if a juvenile 1) commits an offense on or after January 1, 1996, 2) the offense is a felony, and 3) the offense resulted in committing the juvenile to the Texas Youth Commission, then that offense may be used to enhance the punishment range for a felony committed when the juvenile becomes an adult. Id. at § 51.13(d).