In the Interest of W. B., a Child, 342 Ga. App. 277

On Jan 19, 2016 W.B. and two juvenile co-defendants (and an adult) committed a first-degree burglary in Columbus; W.B. admitted the burglary at the juvenile-court hearing.
The State amended the delinquency petition to allege criminal gang activity tied to the "Winston Road Squad," a local subset of the Gangster Disciples.
At the adjudicatory hearing the State presented three witnesses: a patrol officer (O’Keefe), a corrections special agent qualified as a gang expert (Samra), and a school official (Dubose).
Evidence against W.B. consisted largely of Facebook printouts showing hand signs, firearms, emojis (guns/bombs/dollar signs), use of the initials “AG,” photos with persons suspected of gang activity (including a person called “Squad Boss”), and a prior school disciplinary admission referencing gang activity.
The State introduced no evidence that the burglary proceeds benefited the gang, that gang members posted about the burglary on social media, or that the burglary was intended to further the Winston Road Squad’s interests; police reports cited on appeal were not admitted at the hearing and thus not considered.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether evidence showed W.B. committed the burglary to further gang interests under OCGA §16-15-4(a)	Social-media posts, photos with suspected gang members, use of initials, gang signs/colors and prior school gang admission support nexus to gang purpose	State failed to show proceeds, public claim of the burglary, or social-media posts linking this burglary to the gang; no evidence burglary advanced gang interests	Reversed: insufficient evidence of nexus that the burglary was intended to further the Winston Road Squad’s interests

Jones v. State, 292 Ga. 656 (establishes elements required to convict under the Street Gang Act)
Rodriguez v. State, 284 Ga. 803 (requires nexus showing crime intended to further gang activity)
Randolph v. State, 334 Ga. App. 475 (gang statute requires proof beyond mere commission of crime by gang members)
Morris v. State, 340 Ga. App. 295 (social-media references can satisfy nexus when they show crime was claimed to benefit or promote a gang)
Alston v. State, 329 Ga. App. 44 (highly visible crimes intended to signal gang responsibility can satisfy nexus)
In the Interest of X. W., 301 Ga. App. 625 (promotion within gang hierarchy via criminal acts or posts can establish nexus)
In the Interest of A. G., 317 Ga. App. 165 (standard of appellate review in juvenile delinquency adjudications)
Morey v. State, 312 Ga. App. 678 (examples of evidence showing crimes furthered gang interests)
In the Interest of L. P., 324 Ga. App. 78 (retaliatory crimes against rivals can show gang-motivated purpose)
Zamudio v. State, 332 Ga. App. 37 (examples of proof admissible to show gang membership)
White v. State, 310 Ga. App. 386 (appellate review limited to evidence actually admitted at trial)