Case Conclusion Date: 08.12.2012
Practice Area: Juvenile
Outcome: Conviction Reversed
Description: The Court of Appeals reversed a disposition entered against J.X.B. by the Juvenile Court as the Court failed to make sufficient findings of fact. O.C.G.A. 15-11-63 requires the court to consider five factors before imposing a term ofrestrictive custody on a juvenile. The court must reduce its findings to writing. In this case, the court did enter a written order, but the order was issued as a pre-printed form with blank spaces for pertinent information. While the trial court did fill in such blanks, the findings were very general and made no reference to J.X.B. specifically. The Court of Appeals relied on In the Interest of E.D.F., 243 Ga. App. 68 (2000) and other cases for the proposition that the General Assembly intended for the Juvenile Courts to take special care in the imposition of restrictive custody. Specific and detailed inquiry and findings are required by the trial court, such that those findings relate to the particular child in question.