In Re: B.T., E2016-00204-COA-R3-JV

On Oct. 3, 2015 an 11-year-old (B.T.) shot and killed an 8‑year‑old neighbor; juvenile petition alleging first‑degree murder was filed in Jefferson County Juvenile Court.
An adjudicatory hearing was set for Oct. 28, 2015; the State moved to continue twice (first to Dec. 16, then to Jan. 22) citing pending forensic testing (firearms, fingerprints), psychological evaluation, school records, and a requested trajectory analysis.
Juvenile court granted the continuances; B.T. opposed, arguing lack of good cause/extraordinary circumstances under Tenn. R. Juvenile P. 17 and asserting the 90‑day requirement had been breached.
B.T. filed a petition for writ of certiorari and a motion to dismiss with prejudice in Jefferson County Circuit Court challenging the continuances and the hearing delay beyond 90 days; he also argued the circuit court failed to hear his appeal on the merits within 45 days under Tenn. Code Ann. § 37‑1‑159(c).
At the Jan. 6, 2016 circuit hearing the court took the certiorari petition under advisement (did not deny), found the juvenile court acted within discretion in granting continuances to allow forensic testing, and concluded the record did not show the circuit court unlawfully failed to hear the appeal on the merits within 45 days.
Appellate court affirmed the circuit court: no final denial of certiorari to review, juvenile court continuances were within discretion, and record did not establish an unlawful failure to adjudicate within 45 days.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether juvenile court illegally granted two continuances (Tenn. R. Juv. P. 17)	B.T.: continuances lacked good cause/extraordinary circumstances and were illegal	State: continuances were justified to complete forensic testing and evaluations; juvenile court acted within discretion	Court: circuit did not deny certiorari and took petition under advisement; juvenile court’s continuances were within discretion and not illegal
Whether adjudicatory hearing improperly continued beyond 90 days (Tenn. R. Juv. P. 17(a))	B.T.: 90‑day hearing requirement is mandatory and continuances cannot extend it	State: 90‑day goal is intended for timeliness but courts may permissibly hear cases beyond 90 days for legitimate reasons; remedy is dismissal by juvenile court if appropriate	Court: record shows juvenile court reasonably extended beyond 90 days; circuit took certiorari under advisement and did not deny; no relief warranted
Whether circuit court failed to hear appeal on the merits within 45 days (Tenn. Code Ann. § 37‑1‑159(c))	B.T.: circuit court did not adjudicate merits within required 45‑day period, prejudicing him	State: circuit court addressed jurisdictional issues within 45 days and was without power to address merits after finding lack of jurisdiction	Court: record lacks dates and facts to show unlawful delay; circuit addressed jurisdiction within 45 days and dismissal for lack of jurisdiction prevented merits consideration

State v. Lane, 254 S.W.3d 349 (Tenn. 2008) (standard of review for denial or grant of common‑law writ of certiorari is abuse of discretion)
In re Adoption of A.M.H., 215 S.W.3d 793 (Tenn. 2007) (appellate review standard: factual findings presumed correct unless evidence preponderates otherwise)
In re Angela E., 303 S.W.3d 240 (Tenn. 2010) (questions of law are reviewed de novo with no presumption of correctness)