In the Interest of D. C., 307 Ga. App. 542

D.C., a juvenile, was adjudicated delinquent after admitting to two counts of theft by taking—motor vehicle and a violation of probation following a hearing.
He was sentenced to restrictive custody for 24 months under OCGA § 15-11-63 (b).
D.C. appealed pro se through his father, raising ineffective assistance of trial counsel; the appellate court remanded for a hearing on the claim.
At detention, D.C. faced charges for three motor vehicle thefts in Peachtree City; he admitted to one offense and was placed on probation with OTP as a special condition.
D.C. did not complete the Outdoor Therapeutic Program (OTP) and was unsuccessfully discharged on March 8, 2010.
A new delinquency petition based on probation violation and the two remaining theft charges was adjudicated on March 17, 2010, with D.C. admitting to both theft offenses and the probation violation; the court adjudicated delinquency and imposed 24 months of restrictive custody.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the case should be remanded for an evidentiary hearing on ineffective assistance	D.C.'s father argues trial counsel was ineffective.	State requests remand to address ineffectiveness on the existing record.	Remand for an evidentiary hearing on ineffective assistance.

In the Interest of J. L. B., 280 Ga. App. 556 (2006) (parents appealing delinquency adjudication may proceed pro se)
In the Interest of J. L. H., 289 Ga. App. 30 (2007) (parental right to appeal delinquency adjudication)
In the Interest of D. S., 302 Ga. App. 873 (2010) (recognizes appeal rights in delinquency proceedings)
Pinkston v. State, 277 Ga. App. 432 (2006) (ineffective assistance claims may be reviewed on appeal)
Bynum v. State, 300 Ga. App. 163 (2009) (remand for ineffective assistance when record inadequate)
In the Interest of J. B., 223 Ga. App. 429 (1996) (when record suffices, court may decide ineffectiveness without remand)