In the Interest of C. A. J., a Child, 331 Ga. App. 788

Child: C.A.J., born ~2006, lived primarily with maternal grandparents since May 2011 after mother moved out of volatile relationship.
Mother entered into a relationship and later married Phillip Jones, a convicted child molester and registered sex offender; mother permitted Jones access to C.A.J.
C.A.J. disclosed that Jones kissed her and touched her inappropriately; Jones was arrested and charged with child molestation.
Juvenile court suspended mother’s visitation; grandmother filed and pursued a private deprivation petition seeking custody and adoption placement.
After hearings and evidence (mother’s minimal financial support, continued contact with Jones, C.A.J.’s improved condition with grandparents and therapist’s testimony), the juvenile court found C.A.J. deprived and awarded grandmother permanent custody for adoption.
On appeal, this Court affirmed the deprivation finding but held the juvenile court exceeded its authority by awarding permanent custody for adoption without a superior-court transfer.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether evidence supported finding that C.A.J. was a deprived child	Grandmother: mother failed to protect child from sexual abuse, neglected emotional needs, and failed to support child financially, establishing deprivation by clear and convincing evidence	Mother: challenged grandparents’ fitness, claimed she ended relationship with Jones and was improving in therapy	Affirmed: evidence (mother’s relationship with convicted offender, disbelief of child’s outcry, minimal support, ongoing contact with Jones, child’s improved condition with grandparents) supported deprivation finding by clear and convincing evidence
Whether juvenile court could award permanent custody for adoption	Grandmother: sought permanent custody/placement for adoption based on deprivation finding	Mother: (implicitly) challenged custody scope and claimed appropriate process not followed	Reversed: juvenile court lacked authority to award permanent custody for adoption absent a superior-court transfer; disposition remanded for proper custody proceedings

In the Interest of M. M., 315 Ga. App. 673 (Ga. Ct. App.) (standard of review on deprivation appeals)
In the Interest of W. W., 308 Ga. App. 407 (Ga. Ct. App.) (deprivation defined; appellate deference to juvenile court credibility findings)
In the Interest of A. P., 299 Ga. App. 886 (Ga. Ct. App.) (mother’s failure to protect child from sexual abuse supports deprivation)
In the Interest of T. J., 281 Ga. App. 308 (Ga. Ct. App.) (failure to financially support child relevant to deprivation/continued risk)
In the Interest of C-J. N., 289 Ga. App. 423 (Ga. Ct. App.) (failure to protect child can support termination/adoption best interest)
Ertter v. Dunbar, 292 Ga. 103 (Ga.) (juvenile court may award temporary custody in deprivation cases but lacks authority to award permanent custody for adoption without superior-court transfer)
Mauldin v. Mauldin, 322 Ga. App. 507 (Ga. Ct. App.) (juvenile court lacks authority to award permanent custody absent transfer)