J.A.C. v. State, 2013 Ark. App. 496

Appellant J.A.C. was charged with first-degree criminal mischief (felony), theft of property (Class A misdemeanor), and criminal trespass (Class C misdemeanor).
J.A.C. was sixteen at the time of alleged conduct and moved to transfer the case to the juvenile division.
The trial court denied the transfer motion after a hearing.
Arkansas law requires written findings on all ten transfer factors; the order allegedly lacked complete findings.
The court denied the felony transfer but the two misdemeanors were deemed outside the circuit court's jurisdiction.
On appeal, the court affirmed in part and reversed and dismissed in part, remanding jurisdictional issues.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was the finding defect preserved?	J.A.C. argues incomplete findings warrant remand.	State contends defense failed to object, waiving the issue.	Not preserved; cannot review.
Did the circuit court have jurisdiction over the misdemeanors?	Misdemeanors could be charged in criminal division after proper transfer.	No transfer to juvenile division occurred; jurisdiction lacking.	Misdemeanors dismissed without prejudice for lack of jurisdiction.

Williams v. State, 96 Ark. App. 160, 239 S.W.3d 44 (2006) (procedural rights waived by failure to object)
Box v. State, 71 Ark. App. 403, 30 S.W.3d 754 (2000) (objections needed to correct deficiencies in orders)
Butler v. State, 324 Ark. 476, 922 S.W.2d 685 (1996) (jurisdictional limits in transfer rulings)