In re J.R.L.
Georgia Court of Appeals
738 S.E.2d 144 (2013)

- Written by Katrina Sumner, JD
Facts
After huffing computer duster, 16-year-old J.R.L. (defendant) began driving erratically. J.R.L. lost control of the vehicle, narrowly missing a concrete barrier at a gas station because a passenger took the wheel. When J.R.L. gained control again, he was speeding, laughing, and jerking the wheel in a back-and-forth motion. J.R.L. ran a red light and slammed into the back of vehicle carrying a husband, his pregnant wife, and their four children, ranging in age from three to 10 years old. The six-year-old was killed, and the three-year-old was left a quadriplegic and dependent on a ventilator. The wife and the other two children suffered various broken bones. In a delinquency petition, the state (plaintiff) charged J.R.L. with first-degree homicide with a vehicle and various related charges, including driving under the influence. The state also moved to transfer the case to superior court, and a hearing was held in the juvenile court to consider the motion. During the hearing, a supervisor from the Department of Juvenile Justice testified, explaining that the maximum penalty J.R.L. could receive if the case was not transferred was an order committing him to the state’s custody for two years. The supervisor indicated that J.R.L. could be placed in a treatment center for six to nine months, a foster home, or even his own house, but that placement in a detention center was unlikely. After the hearing, the juvenile court assessed factors to balance J.R.L.’s interests with the community’s interests. J.R.L.’s amenability to treatment, lack of criminal history, good grades, and desire to go to college weighed in favor of retaining the case. However, the seriousness of the infraction, the severity of the injuries, J.R.L.’s instigation of the huffing, the limited options for detention, and the desire for a public trial weighed in favor of the community’s interest in having the case transferred to superior court. The court ruled that the factors in favor of the community’s interest outweighed J.R.L.’s interest and permitted the transfer. J.R.L. appealed.
Rule of Law
Issue
Holding and Reasoning (Barnes, J.)
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