State v. Harris, 319 Ga. 665

Bjorn Harris, a 15-year-old, was arrested for murder and related charges following the shooting death of Jaylan Major and detained at a youth facility.
Harris was first indicted in July 2023 for voluntary manslaughter and other charges, within 180 days of his detention, as required under Georgia law.
In November 2023, Harris was reindicted on murder and additional charges, after the initial indictment was nolle prossed (dropped at the State's request).
Harris moved to transfer his case to juvenile court, arguing that the reindictment fell outside the statutory 180-day window since his detention.
The superior court granted Harris's motion to transfer, relying on previous interpretations of the statutory 180-day requirement, and the State appealed the transfer order to the Georgia Supreme Court.

Issue	Harris's Argument	State's Argument	Held
Whether OCGA § 17-7-50.1 requires transfer to juvenile court if reindictment occurs after 180 days	Failure to indict on murder charges within 180 days requires transfer	Any true bill on qualifying charges within 180 days is sufficient, reindictment timing is irrelevant	The statute only requires a true bill within 180 days on at least one qualifying charge; transfer not required
Whether the language "the charge" requires all final charges to be presented to grand jury in 180 days	Yes, so new charges added later are untimely	No, statute satisfied by timely indictment on any qualifying superior court charge	The statutory text does not require every final charge to be presented within 180 days
Whether a nolle prossed first indictment affects the superior court's jurisdiction	Yes, if charges are dropped and refiled late, jurisdiction is lost	No, timely return of a true bill suffices, regardless of later indictment modifications	Timely initial indictment keeps superior court jurisdiction regardless of later reindictment
Whether Armendariz precedent required transfer for late reindictments	Yes, per Armendariz, any late reindictment requires transfer	Armendariz was wrongly decided, not supported by statute	Armendariz overruled; timely initial indictment controls

State v. Coleman, 306 Ga. 529 (explains principle of statutory interpretation and 180-day rule for detained children)
Smith v. State, 279 Ga. 396 (reindictment before trial is permissible unless explicitly barred by statute)
State v. Heath, 308 Ga. 836 (State generally allowed to re-indict prior to trial)