## Facts

- Sixteen-year-old J.R.L. inhaled (“huffed”) computer duster and then began driving erratically late at night on July 1, 2011.
- J.R.L. lost control of the vehicle and nearly struck a concrete barrier near a gas-station entrance; a passenger briefly took the steering wheel to avoid the barrier.
- After J.R.L. regained control, he drove at high speed, laughed, and jerked the steering wheel back and forth in an intentionally erratic manner.
- J.R.L. ran a red light and slammed into the rear of another vehicle carrying a husband, his pregnant wife, and their four children (ages three to 10).
- One child (age six) was killed; another child (age three) suffered permanent quadriplegia and became dependent on a ventilator.
- The wife and two other children suffered multiple broken bones and other injuries.
- The State filed a delinquency petition in juvenile court alleging first-degree vehicular homicide and related offenses, including driving under the influence.
- The State moved to transfer the case to superior court for adult prosecution under O.C.G.A. § 15-11-30.2(a), and the juvenile court held a transfer hearing.
- A Department of Juvenile Justice supervisor testified that, if the case stayed in juvenile court, the maximum commitment would be two years in state custody; placement could include a treatment center (roughly six to nine months), a foster home, or even J.R.L.’s home, and placement in a detention center was unlikely.
- The juvenile court weighed J.R.L.’s lack of prior record, good grades, desire to attend college, and evidence of treatment amenability against the seriousness of the conduct, the extreme harm, evidence that J.R.L. instigated the huffing, the limited confinement options in the juvenile system, and the community’s interest in a public trial.
- Concluding that the community’s interest outweighed J.R.L.’s interest in remaining in juvenile court, the juvenile court ordered transfer to superior court.
- J.R.L. appealed, claiming the juvenile court abused its discretion in ordering transfer.

## Issues

1. Did the juvenile court abuse its discretion under O.C.G.A. § 15-11-30.2(a) by transferring J.R.L.’s case to superior court based on its finding that the interests of the child and the community required legal restraint and transfer?
2. On appeal from a juvenile transfer order, is the reviewing court limited to determining whether some evidence supports the juvenile court’s statutory findings, rather than reweighing the evidence?

## Decision

- The Court of Appeals of Georgia affirmed the transfer order.
- The court held that a transfer order is a final order that may be directly appealed.
- Applying a deferential standard, the court explained its role was limited to deciding whether there was some evidence supporting the juvenile court’s findings under O.C.G.A. § 15-11-30.2(a); absent an abuse of discretion, the transfer must be affirmed.
- The record contained some evidence supporting the required statutory findings, including reasonable grounds to believe J.R.L. committed the charged acts, that he met the age requirement, and that he was not committable to a mental institution.
- The court also found some evidence supported the juvenile court’s conclusion that the gravity of the alleged conduct and the severe consequences, combined with the short and less-secure juvenile dispositions available, supported transfer in the interests of the community and the child.

## Legal Principles

- An order transferring a case from juvenile court to superior court is a final, directly appealable order.
- Under O.C.G.A. § 15-11-30.2(a), before transferring jurisdiction the juvenile court must find reasonable grounds to believe: (1) the child committed the alleged delinquent act, (2) the child is not committable to an institution for the mentally ill or mentally retarded, (3) the interests of the child and the community require legal restraint and transfer, and (4) the child was at least 15 at the time of the alleged conduct.
- Appellate review of a transfer order is highly deferential: the reviewing court asks only whether some evidence supports the juvenile court’s statutory findings and will not reweigh the evidence; absent an abuse of discretion, the order is affirmed.
- In assessing whether the interests of the child and community require transfer, the juvenile court may consider the seriousness of the alleged offense, the extent of harm, the child’s conduct leading to the harm, treatment amenability, and the practical limits of available juvenile dispositions given the child’s age and the court’s jurisdictional time limits.

## Conclusion

The Court of Appeals of Georgia affirmed the juvenile court’s order transferring J.R.L.’s case to superior court for adult prosecution, holding that the transfer findings required by O.C.G.A. § 15-11-30.2(a) were supported by some evidence and that the juvenile court acted within its discretion when it concluded that the severe loss of life and injuries and the limited juvenile sanctions justified transfer.


In re J.R.L., 738 S.E.2d 144 (2013)