In Re Jw, 309 Ga. App. 470

J.W. was adjudicated delinquent for armed robbery, aggravated assault, and battery based on a 2009 commitment order.
J.W. admitted possession of a firearm as a minor; the case proceeded to a stipulated bench trial on possession of a firearm by a convicted felon.
State charged J.W. with possession of a pistol or revolver by a person under 18 and possession of a firearm by a convicted felon under OCGA § 16-11-131(b).
Trial relied on the 2009 delinquency adjudications to prove a prior felony for the felon-in-possession charge.
Georgia appellate court held juvenile delinquency adjudications are not criminal convictions sufficient to support a felon-in-possession adjudication under OCGA § 16-11-131(b).
Court reversed the delinquency adjudication for possession of a firearm by a convicted felon on this basis.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether juvenile delinquency adjudications constitute criminal convictions for OCGA § 16-11-131(b).	JW argues delinquency adjudications are not criminal convictions.	State argues adjudications can be used to prove prior felony status for felon-in-possession.	Delinquency adjudications are not criminal convictions for this statute.

A.B.W. v. State, 231 Ga. 699, 203 S.E.2d 512 (1974) (Ga. 1974) (juvenile court cannot convict a juvenile of a crime; adjudication is delinquency, not conviction)
In re L.C., 273 Ga. 886, 548 S.E.2d 335 (2001) (Ga. 2001) (restrictive custody is not a criminal conviction; chiefly rehabilitative)
In the Interest of D.T.C., 226 Ga.App. 364, 487 S.E.2d 21 (1997) (Ga. App. 1997) (non-criminal nature of juvenile delinquency adjudication; limitations on parallel reasoning with crimes as adults)
Carrindine v. Ricketts, 236 Ga. 283, 223 S.E.2d 627 (1976) (Ga. 1976) (cited regarding distinctions between criminal conviction and juvenile adjudication)
Jackson v. Virginia, 443 U.S. 307, 99 S. Ct. 2781, 61 L. Ed. 2d 560 (1979) (U.S. 1979) (standard for appellate review of sufficiency of evidence)