In the Interest of A.G., a Child, A22A0459

In November 2020, then-16-year-old A.G. shot his mother’s boyfriend, Elijah Winn, multiple times; Winn survived after extensive hospitalization and surgeries.
The State filed a juvenile delinquency petition alleging acts that would be felonies if committed by an adult (attempted murder, aggravated assault, aggravated battery, cruelty to children, criminal trespass).
The State moved to transfer A.G.’s case to superior court; the juvenile court held a transfer hearing, heard witnesses, and received a psychological evaluation finding A.G. amenable to treatment.
At the hearing the juvenile court admitted evidence of Winn’s prior domestic-violence arrest and excluded an Instagram video the State sought to use as A.G.’s prior bad act for lack of notice/authentication.
The juvenile court denied the State’s motion to transfer, emphasizing A.G.’s age, lack of prior juvenile history, and the psychologist’s conclusion that he could benefit from juvenile rehabilitative services.
The State appealed, challenging (1) denial of transfer for improper weighting of statutory factors, (2) exclusion of A.G.’s alleged prior bad act, and (3) admission of Winn’s prior act; the Court of Appeals affirmed.

Issue	Plaintiff's Argument (State)	Defendant's Argument (A.G.)	Held
Whether juvenile court erred in denying transfer under OCGA § 15-11-562	Juvenile court improperly weighed statutory factors and should have transferred due to offense seriousness	Court properly considered factors and reasonably concluded rehabilitation in juvenile system served community better	Affirmed — some evidence supported court’s findings; no abuse of discretion
Whether court erred by excluding State’s proffered prior bad-act Instagram video	Evidence should have been admissible at transfer; notice requirement doesn’t apply to transfer hearings	State failed to provide required § 24-4-404(b) notice and authentication was doubtful	Affirmed — rules of evidence apply to transfer hearings; exclusion for lack of notice not an abuse of discretion
Whether court erred by admitting evidence of Winn’s prior domestic-violence arrest	Admission was improper and prejudicial	Evidence was relevant to A.G.’s home/environment and to factor (9) (maturity/situation)	No reversible error — even if admission was erroneous, it did not affect a substantial right or the transfer outcome

In the Interest of C. M., 356 Ga. App. 368 (Court of Appeals) (appellate review of transfer limited to whether some evidence supports juvenile court)
In the Interest of K. S., 303 Ga. 542 (Supreme Court of Georgia) (transfer decisions directly appealable to Court of Appeals)
Smart v. State, 299 Ga. 414 (Supreme Court of Georgia) (three-part test for admissibility of other-acts evidence)
Parker v. State, 296 Ga. 586 (Supreme Court of Georgia) (Georgia evidence rules apply to fact-finding proceedings including transfer hearings)
Jones v. State, 352 Ga. App. 380 (Court of Appeals) (evidentiary rulings reviewed for abuse of discretion)
Strong v. State, 309 Ga. 295 (Supreme Court of Georgia) (victim’s specific violent acts may be admissible to show defendant’s state of mind in self-defense context)
In the Interest of B. J. W., 247 Ga. App. 437 (Court of Appeals) (failure to make required balancing findings can require remand)