In Re Jc, 708 S.E.2d 1

Sixteen-year-old J.C. was adjudicated delinquent for shoplifting.
Security guard observed J.C. conceal a Polo hat on CCTV and J.C. left the store within a minute.
J.C. claimed the hat was not in his possession when apprehended.
Guard testified from live observation via CCTV, not from a video recording admitted into evidence.
The juvenile court denied a motion for rehearing; the associate judge’s findings were reviewed de novo under OCGA § 15-11-21(e).
The Court of Appeals affirmed the delinquency adjudication in part, reversed in part on rehearing issues, and remanded for de novo disposition.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admissibility of guard’s testimony based on CCTV	J.C. argues the testimony relied on a video not admitted.	State contends guard observed events live, not hearsay.	Testimony was not hearsay; based on live observation via CCTV.
Sufficiency of evidence to prove shoplifting	Guard’s reliability may be questionable; possession not clearly shown.	Concealing hat with intent suffices, even if not leaving store with it.	Evidence properly supports delinquency; intent inferred from concealment and actions.
De novo rehearing review under OCGA § 15-11-21(e)	Judge failed to provide proper de novo findings.	Judge conducted de novo review.	Order denying rehearing defective; remand for proper de novo disposition.

In the Interest of T. T., 236 Ga.App. 46 (1999) (standard of review for delinquency adjudications; Jackson v. Virginia analysis)
In the Interest of C.G., 261 Ga.App. 814 (2003) (live observation not hearsay when witness saw event unfold; videotape not admitted)
In the Interest of C.F., 255 Ga.App. 620 (2002) (rehearing standards; evidence sufficiency considerations)
In re M.E.T., 197 Ga.App. 255 (1990) (de novo review required after rehearing request; not mere appellate review)
In the Interest of W.M.F., 180 Ga. App. 397 (1986) (rehearing procedures for juvenile cases; de novo determination required)