State v. Coleman, 306 Ga. 529

Vas Coleman, age 16 at arrest, was charged in Fulton County, GA with felony murder and burglary in connection with Jose Greer’s 2015 death; Fulton Superior Court had exclusive jurisdiction under OCGA § 15-11-560(b)(1).
Coleman was arrested on February 17, 2016, detained at Fulton County Youth Detention Center, released on bond March 24, 2016.
An April 8, 2016 grand jury indicted Coleman; that indictment was later nolle prossed. A March 20, 2018 grand jury re-indicted him on the same charges.
Coleman moved to transfer the case to juvenile court, arguing the March 2018 indictment was beyond the 180-day limit in OCGA § 17-7-50.1 because the 180-day clock had begun on his initial detention in 2016.
The trial court granted the transfer, relying on Court of Appeals precedents (Edwards and Armendariz) interpreting “who is detained” and the 180-day period as tied to the date of detention rather than continuous custody.
The Georgia Supreme Court reversed: it held the 180-day statutory protection applies only while the juvenile remains detained (i.e., in custody), and does not run while the juvenile is released on bond; it overruled Edwards.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Coleman)	Held
Whether the 180-day grand-jury presentation requirement in OCGA § 17-7-50.1 applies when a juvenile was detained at the start but released before 180 days elapsed	The 180-day clock runs from the date of detention regardless of subsequent release; statute protects those "who are detained" as of that date	The 180-day clock began on the date of detention and runs even if the juvenile is released before 180 days, so failure to indict within 180 days requires transfer	Held for State: the statute applies only while the juvenile remains detained; release on bond stops the running of the 180-day period (Edwards overruled)
Whether the trial court erred in transferring Coleman’s case to juvenile court based on the post-release timing of the re-indictment	Transfer was improper because the 180-day limit did not run while Coleman was released on bond; superior court retained jurisdiction	Transfer was proper because the 2018 indictment came after 180 days from initial detention, so superior court lost jurisdiction and juvenile court should hear the case	Held for State: trial court erred in ordering transfer; superior court jurisdiction preserved

Edwards v. State, 323 Ga. App. 864 (Court of Appeals of Ga.) (Court of Appeals decision construing "who is detained" as a point-in-time rule; overruled by this decision)
State v. Armendariz, 316 Ga. App. 394 (Court of Appeals of Ga.) (relied on Edwards on similar statutory interpretation)
Tatis v. State, 289 Ga. 811 (Ga.) (construing OCGA § 17-7-50 as applying only to confined adults)
State v. English, 276 Ga. 343 (Ga.) (discussing timely grand-jury presentation for confined defendants)
Rawls v. Hunter, 267 Ga. 109 (Ga.) (related precedent on confinement and grand-jury timing)
Burke v. State, 234 Ga. 512 (Ga.) (earlier precedent on confinement and grand-jury deadlines)