In the Interest of J. F., a Child

789 S.E.2d 274, 338 Ga. App. 15
CourtCourt of Appeals of Georgia
DecidedJuly 12, 2016
DocketA16A0395
StatusPublished
Cited by6 cases

This text of 789 S.E.2d 274 (In the Interest of J. F., a Child) is published on Counsel Stack Legal Research, covering Court of Appeals of Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In the Interest of J. F., a Child, 789 S.E.2d 274, 338 Ga. App. 15 (Ga. Ct. App. 2016).

Opinions

Dillard, Judge.

This Court is faced with a unique dilemma. On the one hand, the Georgia Constitution dictates that we decide each case within two terms of being docketed. On the other hand, that same Constitution also requires us to respect our place in this state’s judicial hierarchy and steadfastly avoid encroaching upon the Supreme Court of Georgia’s exclusive jurisdiction or domain. But in order to decide the case before us, we must choose between two conflicting precedents that are [16]*16currently being reviewed by our Supreme Court as part of its certio-rari process. And while our constitutional duty to decide cases within two terms of docketing may well authorize us to make this choice, we think that it is inadvisable to do so. Instead, we choose to exercise our authority under Article VI, Section V, Paragraph IV of the Georgia Constitution and certify the question presented in this case to our Supreme Court “for instruction,” to which we “shall then be bound.” We do not take this action lightly. And in doing so, we fully recognize that this Court is treading into murky jurisprudential waters. But faced with the choice of carving out a narrow (and perhaps temporary) exception to this state’s certification jurisprudence or disrupting our Supreme Court’s certiorari process, we choose the former.

Before fleshing out our reasoning for certifying the question presented in this case to our Supreme Court, we will briefly describe the procedural context of the case, as well as the parties’ respective arguments. Specifically, J. F. appeals from the juvenile court’s denial of his motion to dismiss the State’s case against him with prejudice for failure to comply with OCGA § 15-11-521 (b). He argues that because the State failed to file a delinquency petition within 30 days after his release from detention and neglected to seek an extension of time to file same, the trial court was required to dismiss the State’s case with prejudice.

The undisputed facts show that J. F. was detained on January 30, 2015, and charged with robbery by sudden snatching and aggravated assault. The juvenile court released him from custody following a February 2, 2015 detention hearing. But then, on March 16, 2015, J. F. moved to dismiss the case with prejudice due to the State’s failure to file a delinquency petition.

On March 17, 2015, acknowledging that no delinquency petition had been filed within 30 days of J. F.’s release from custody as required by OCGA § 15-11-521 (b), the State simultaneously administratively dismissed the complaint and filed a new complaint identical to the one it had just dismissed. Then, the State filed a delinquency petition within 30 days of the new complaint.

At a March 25, 2015 hearing on J. F.’s motion to dismiss, the assistant district attorney explained that no delinquency petition had been timely filed within 30 days of J. F.’s release because, in the course of implementing a new organizational system within her office, J. F.’s case hadbeen overlooked. The assistant district attorney further informed the court that (1) her office’s procedure was to administratively dismiss and then re-file complaints when the original time limit was missed, and (2) a motion for an extension of time had not been filed because she thought such a motion “would just be [17]*17a waste of the court’s time.” Ultimately, the trial court denied J. F.’s motion to dismiss with prejudice, and this interlocutory appeal follows.

As always, our analysis necessarily begins with the text of the relevant statute, i.e., OCGA § 15-11-521 (b), which provides:

If a child is not in detention prior to adjudication, a petition alleging delinquency shall be filed within 30 days of the filing of the complaint alleging violation of a criminal law or within 30 days of such child’s release pursuant to a determination that detention is not warranted. Upon a showing of good cause and notice to all parties, the court may grant an extension of time for filing a petition alleging delinquency The court shall issue a written order reciting the facts justifying any extension.

This Court recently addressed this Code section in two procedurally similar cases, which were issued just three days apart: In the Interest of M. D. H.,1 decided on November 10, 2015, and In the Interest of D. V. H.,2 decided on November 13, 2015. However, on March 7, 2016, the Supreme Court of Georgia issued an order granting petitions for a writ of certiorari in both cases.3 In doing so, our Supreme Court indicated that it was “particularly concerned” with whether this Court “correctly applied OCGA § 15-11-521 (b).”4

Again faced with the issue we addressed in M. D. H. and D. V.H., we recognize—as we did on motion for reconsideration in D. V. H.5— that there is tension between the analyses employed in those cases. Indeed, the particular facts of this case, as well as our Supreme Court’s decision to grant certiorari in M. D. H. and D. V.H., make this tension even more palpable. This tension, of course, should and must be resolved. And our Supreme Court has strongly signaled its intent to do just that with its consolidated grant of certiorari as to both of those cases. Nevertheless, some members of this Court propose that we should take the opportunity afforded by this case to revisit, clarify, and resolve the tension between M. D. H. and D. V. H. by overruling M. D. H. We think this course of action is inadvisable. To overrule—or even substantially revise or clarify—one of these cases would disrupt [18]*18the status quo of the very precedents now pending before our Supreme Court and encroach upon that court’s constitutional authority to review this Court’s decisions.6 This brings us back to the question of whether certifying this case to the Supreme Court of Georgia is appropriate.

As previously noted, we are only faced with this unique dilemma because of Georgia’s constitutionally mandated two-term rule.7 Unlike federal courts, we are not at liberty to delay the disposition of appeals in anticipation of pending decisions from the Supreme Court of the United States or our own Supreme Court.8 We have concluded, then, that the only meaningful course of action is for this Court to certify the question presented in this case to our Supreme Court for its consideration along with M. D. H. and D. V.H., as is permitted by the Constitution of the State of Georgia.9

In taking this course of action, we are mindful that our Supreme Court has previously held that “[a] certified question of law and fact will not be answered and, even if the question certified is one of law only, it will not be answered if such answer would necessarily control the decision of the case.”10

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Related

In the Interest Of: J. F., a Child
809 S.E.2d 845 (Court of Appeals of Georgia, 2018)
In the Interest of J. F.
797 S.E.2d 921 (Supreme Court of Georgia, 2017)
In the Interest of J.F., a Child
Supreme Court of Georgia, 2017
BRIDGES Et Al. v. COLLINS-HOOTEN Et Al.
792 S.E.2d 721 (Court of Appeals of Georgia, 2016)
In the Interest of M. D. H.
793 S.E.2d 49 (Supreme Court of Georgia, 2016)

Cite This Page — Counsel Stack

Bluebook (online)
789 S.E.2d 274, 338 Ga. App. 15, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-the-interest-of-j-f-a-child-gactapp-2016.