State v. Jones, 392 S.C. 647

Jones, age 15, was charged as a juvenile with murder, armed robbery, and unlawful pistol possession.
The family court waived jurisdiction and transferred the case to the circuit court to be treated as an adult.
Pursuant to a plea agreement, Jones pled guilty to voluntary manslaughter; State dismissed armed robbery and conspiracy and recommended a 20-year cap.
Circuit court sentenced Jones to 20 years with time served credit; Jones appealed challenging waiver and admissibility of a police statement.
The State argues the family court properly applied Kent factors and that the challenged statement was not properly preserved for appeal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Waiver of juvenile jurisdiction under Kent factors	Jones argues the Kent factors were not properly applied.	State contends the court properly weighed and documented the Kent factors.	Family court did not abuse discretion; proper Kent-factor analysis and findings.
Voluntariness of the statement and preservation	Jones contends the statement was involuntary due to absence of mother and officer inducement.	State maintains the issue was not properly preserved and argument is unfounded.	Issue deemed unpreserved/abandoned; no reversal on voluntariness.

Kent v. United States, 383 U.S. 541 (1966) (establishes Kent factors for juvenile waiver)
State v. Pittman, 373 S.C. 527, 647 S.E.2d 144 (2007) (requires best-interest and discretionary juvenile transfer analysis)
State v. Avery, 333 S.C. 284, 509 S.E.2d 476 (1998) (requires sufficient statement of reasons for transfer and full consideration)
In re Sullivan, 274 S.C. 544, 265 S.E.2d 527 (1980) (importance of a careful, fully investigated order in transfer decisions)
State v. Michael H., 360 S.C. 540, 602 S.E.2d 729 (2004) (abandonment and preservation principles on appeal)