## Facts

- Two juvenile brothers (ages 16 and 13) were accused of leaving a self-service store without paying for paperback books and magazines valued at about $25.
- A clerk, alone in the store, testified she suspected the boys had items hidden under their shirts based on bulges and a glimpse of books, but she did not see any taking.
- The clerk allowed the boys to leave, then notified police; police returned the boys to the store and the clerk identified them.
- No missing merchandise was found on the boys, and a neighborhood search did not locate the publications.
- The juvenile court conducted a joint adjudicatory hearing, found both boys delinquent, and at disposition placed each on twelve months’ probation conditioned on payment of $7.50 restitution to the merchant.

## Issues

1. Whether the Georgia Juvenile Court Code authorized a juvenile court to require restitution to the victim as a condition of juvenile probation.

## Decision

- The Court of Appeals of Georgia affirmed the delinquency adjudications and the dispositional orders.
- The court held the Juvenile Court Code empowered the juvenile court to impose restitution as a condition of probation.
- The court concluded the restitution procedure and amount were supported by the record and within the court’s discretion.

## Legal Principles

- The Juvenile Court Code is to be liberally construed to advance its rehabilitative purpose of restoring children, when possible, as law-abiding members of society.
- Juvenile probation is a rehabilitative disposition, and courts may impose reasonable probation conditions tied to the offense and the child’s rehabilitation.
- Restitution in juvenile cases may be treated as rehabilitative and victim-compensatory, distinct from a penal fine payable to the government.
- Even if the Code does not list “restitution” as an express disposition, statutory purpose and structure may permit restitution as an implied probation condition when reasonably related to rehabilitation and the harm caused.

## Conclusion

The court upheld juvenile probation conditioned on victim restitution, reasoning that the Juvenile Court Code’s rehabilitative aims and liberal construction authorize restitution as a reasonable probation condition and that the amount imposed was adequately supported by the evidence.


P.R. v. State, 210 S.E.2d 839 (Ga. Ct. App. 1974)