Raymond Hidalgo, Jr., Appellant v. the State of Texas

Summary

The Texas Court of Criminal Appeals affirmed the lower courts, holding that a juvenile's Sixth Amendment right to counsel does not require prior notice of a court‑ordered psychological examination used in a transfer proceeding. The Court reasoned that the exam serves a neutral, statutory purpose and is not a "critical stage" of the adversarial process, so counsel need not be notified before it occurs. The Court also affirmed that the Sixth Amendment does apply to juveniles in criminal prosecutions, but not to the pre‑transfer examination. Justice Keller, in a concurring opinion, argued that statutory notice of the exam suffices, while Justice Meyers dissented without opinion.