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

J.A.C., sixteen, was charged with first-degree criminal mischief (felony), theft of property (misdemeanor), and criminal trespass (misdemeanor).
Appellant moved to transfer the case to the juvenile division of the circuit court; motion was denied after a hearing.
Arkansas Code § 9-27-318(g) requires ten factors to be considered at a transfer hearing and § 9-27-318(h)(1) requires written findings on all factors.
Appellant argued the order lacked complete written findings on several factors.
The appellate court held the trial court failed to make findings on at least one factor but treated preservation of the issue as lacking due to no objection by appellant.
Court affirmed the denial of transfer for the felony charge but dismissed the two misdemeanors for lack of circuit court jurisdiction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was there error in the transfer order for incomplete findings?	J.A.C. argues findings were incomplete.	State argues defect waived without objection per Williams.	No remand; preservation defective, so no relief on findings.
Does the order affect jurisdiction of the misdemeanor charges?	J.A.C. contends court could transfer all charges.	State argues misdemeanors improperly filed in criminal division without transfer order.	Misdemeanors are dismissed without prejudice due to lack of jurisdiction.

Williams v. State, 96 Ark. App. 160 (2006) (waiver for nonobjected statutory noncompliance; failure to object precludes review)
Box v. State, 30 S.W.3d 754 (Ark. App. 2000) (procedural rights waived by failure to object)
Butler v. State, 922 S.W.2d 685 (Ark. 1996) (misdemeanors in criminal division without proper transfer order)