In THE INTEREST OF T.B., a Child, 313 Ga. 846

T.B., a 16-year-old, was charged in juvenile court with multiple offenses (including aggravated assault on a peace officer, aggravated battery, obstruction, drug possession, and trespass) arising from an incident in which he allegedly assaulted officers and had marijuana/paraphernalia.
After a detention hearing, T.B. was involuntarily hospitalized for psychosis/delusions and later diagnosed with psychotic-spectrum disorders; a forensic psychologist subsequently found him competent to proceed.
Before adjudication, T.B. gave notice he intended to assert insanity or delusional-compulsion defenses and moved for a forensic psychological evaluation to assess whether he could appreciate wrongfulness at the time of the acts.
The juvenile court denied the motion, ruling insanity/delusional-compulsion defenses are unavailable in delinquency proceedings because delinquency adjudications are not criminal convictions and the Juvenile Code does not expressly authorize those defenses.
The State’s appellate position changed; after interlocutory procedures, the Georgia Supreme Court reviewed the question and vacated the juvenile court’s order, remanding for reconsideration consistent with its opinion.

Issue	Plaintiff's Argument (T.B.)	Defendant's Argument (State / Juvenile Court)	Held
Whether a child charged with a delinquent act based on a crime may assert insanity or delusional-compulsion defenses (OCGA §§16-3-2, 16-3-3) in juvenile adjudication.	T.B.: Juvenile Code’s purpose and due process require permitting insanity/delusional-compulsion defenses; he sought forensic evaluation.	Juvenile court/initial State: Juvenile proceedings are not criminal convictions; the Juvenile Code does not expressly provide these defenses, so they are unavailable.	Held: A child may assert insanity or delusional-compulsion defenses in delinquency proceedings when the charge is based on an act "designated a crime," and denial of a forensic evaluation was erroneous.
Whether the Juvenile Code’s limited express reference to alibi implies other affirmative defenses are excluded.	T.B.: The Code’s silence does not bar other defenses; preamble and statutory context favor permitting defenses that negate a delinquent act.	Juvenile court: Specific provision for alibi means other affirmative defenses are not provided.	Held: Rejected; specific procedural rules for alibi do not imply exclusion of other defenses and such an interpretation would conflict with the Code’s purpose.

Clark v. State, 245 Ga. 629 (Ga. 1980) (recognizing insanity defenses in Criminal Code)
McClure v. State, 306 Ga. 856 (Ga. 2019) (insanity is an affirmative defense)
Jackson v. State, 301 Ga. 878 (Ga. 2017) (discussing burden to prove affirmative insanity defense)
McElrath v. State, 308 Ga. 104 (Ga. 2020) (defining delusional-compulsion elements)
Rockdale County v. U.S. Enterprises, Inc., 312 Ga. 752 (Ga. 2021) (statutory construction and in pari materia principles)
Zaldivar v. Prickett, 297 Ga. 589 (Ga. 2015) (rejecting interpretations that render statutory language nonsensical)
City of Marietta v. Summerour, 302 Ga. 645 (Ga. 2017) (treating codified preambles as part of statutory context)