In Re HA, 311 Ga. App. 660

A juvenile court adjudicated H.A. delinquent for burglary in violation of OCGA § 16-7-1 based on fingerprint evidence alone.
The only link tying H.A. to the burglary was a latent fingerprint found on a bottle of tonic water moved during the burglary; the victim never met H.A.
The State had to prove the delinquency beyond a reasonable doubt using the Jackson v. Virginia standard.
The defense argued an alternative hypothesis: H.A. may have left the fingerprint on the bottle before it entered the home, while the bottle was in the stream of commerce.
The trial court rejected the alternative hypothesis and found the fingerprint proof sufficient to adjudicate delinquency.
This Court affirmed, holding the alternative hypothesis unsupported by the record and that the fingerprint evidence, viewed with proper standard, was sufficient.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Is fingerprint evidence alone sufficient to sustain delinquency beyond a reasonable doubt?	H.A. as the sole link; fingerprint on bottle supports guilt.	Alternative explanations must be excluded; fingerprint could be from non-criminal handling.	Yes; evidence sufficient to sustain delinquency.
Was the trial court required to accept HA's alternative hypothesis that the fingerprint predated the crime?	Alternative hypothesis raises no supported evidence; court properly rejected it.	Alternative hypothesis may be reasonable and should have been considered.	No; alternative hypothesis not reasonably supported by evidence; proper rejection.
Did the court properly apply the circumstantial-evidence standard for delinquency verdicts?	Circumstantial evidence can sustain a conviction if it excludes other reasonable hypotheses.	Alternative hypotheses must be reasonably possible and supported by record.	Yes; the record excludes reasonable alternative hypotheses and supports the adjudication.

Leonard v. State, 269 Ga. 867, 506 S.E.2d 853 (1998) (fingerprint on bottles may sustain conviction when only link exists)
White v. State, 253 Ga. 106, 317 S.E.2d 196 (1984) (fingerprint on private item in victim's room can sustain conviction)
Massey v. State, 247 Ga. App. 827, 545 S.E.2d 66 (2001) (fingerprints on items at scene constitute sufficient circumstantial evidence)
Lighten v. State, 259 Ga. App. 280, 576 S.E.2d 658 (2003) (fingerprint evidence supporting burglary conviction when no alternative explanation)
Brown v. State, 180 Ga. App. 188, 348 S.E.2d 575 (1986) (trier may infer imprint at time of burglary absent contrary evidence)
Garland v. State, 160 Ga. App. 97, 286 S.E.2d 330 (1981) (upholding conviction where no evidence for alternative explanation)
Rivers v. State, 271 Ga. 115, 516 S.E.2d 525 (1999) (where no alternative explanation exists, jury may accept only reasonable explanation)
In the Interest of Q.P., 286 Ga. App. 225, 648 S.E.2d 731 (2007) (whether an alternative hypothesis is reasonable is for the factfinder)
In the Interest of A.A., 293 Ga. App. 827, 668 S.E.2d 323 (2008) (standard for reviewing sufficiency of evidence in juvenile delinquency)