In THE INTEREST OF T.B., a Child

313 Ga. 846
CourtSupreme Court of Georgia
DecidedJune 1, 2022
DocketS22A0287
StatusPublished
Cited by13 cases

This text of 313 Ga. 846 (In THE INTEREST OF T.B., a Child) is published on Counsel Stack Legal Research, covering Supreme Court 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 T.B., a Child, 313 Ga. 846 (Ga. 2022).

Opinion

313 Ga. 846 FINAL COPY

S22A0287. IN THE INTEREST OF T. B., a child.

COLVIN, Justice.

This case requires us to determine whether a child charged

with delinquency based on an alleged violation of Georgia’s Criminal

Code may assert an affirmative defense of insanity or delusional

compulsion, under OCGA § 16-3-2 or 16-3-3, in a juvenile-court

proceeding. The Juvenile Code does not expressly state whether

affirmative defenses provided for in the Criminal Code are available

in juvenile court. Based on the Juvenile Code’s text and structure,

however, we conclude that insanity and delusional-compulsion

defenses are available in most delinquency proceedings. As

explained below, we specifically hold that, in a delinquency

proceeding, a child may assert an insanity or delusional-compulsion

defense under OCGA § 16-3-2 or 16-3-3 when the child’s delinquency

charge is based on an allegation that the child committed “[a]n act . . . designated a crime by the laws of this state.” OCGA § 15-11-2 (19)

(A). Because the juvenile court erred in concluding that a child could

never raise an insanity or delusional-compulsion defense in a

delinquency proceeding, we vacate the court’s order denying the

motion of T. B., a minor, which sought a forensic psychological

evaluation for purposes of raising a defense under OCGA § 16-3-2 or

16-3-3, and we remand the case for further proceedings consistent

with this opinion.

1. In 2019, the State filed a delinquency petition in juvenile

court, alleging that T. B. was a delinquent child. According to the

petition, on January 24, 2019, T. B., who was then 16 years old,

attempted to evade the police by entering a hotel in Savannah and

locking himself in the hotel’s storage closet. When officers

attempted to remove T. B. from the closet, the petition alleged, T. B.

pushed the officers, attempted to strike and bite the officers, and

assaulted one officer with liquid glass cleaner, which T. B. poured

on the officer’s face such that some of the liquid went down the

officer’s throat. The petition further alleged that officers found

2 marijuana and marijuana-related paraphernalia in T. B.’s

possession. Based on these allegations, the petition charged T. B.

with aggravated assault on a peace officer, see OCGA § 16-5-21,

aggravated battery, see OCGA § 16-5-24, two counts of obstruction

of an officer, see OCGA § 16-10-24 (b), possession of less than an

ounce of marijuana, see OCGA § 16-13-30 (j), two counts of

possession of drug-related objects, see OCGA § 16-13-32.2, and two

counts of criminal trespass, see OCGA § 16-7-21 (a) and (b).

Following a detention hearing, the juvenile court ordered that

T. B. receive a psychological evaluation and be released the next day

on house arrest with conditions. Before he was released, however,

T. B. was involuntarily hospitalized for several days, pursuant to

OCGA § 37-3-41 (a),1 because he was experiencing symptoms of

psychosis, including delusions.

Approximately four months later, a forensic psychologist

1 See OCGA § 37-3-41 (a) (“Any physician within this state may execute

a certificate stating that he or she has personally examined a person within the preceding 48 hours and found that, based upon observations set forth in the certificate, such person appears to be a mentally ill person requiring involuntary treatment.”). 3 performed a competency evaluation. The psychologist noted that T.

B. had previously been diagnosed with, among other things,

Unspecified Schizophrenia Spectrum and Other Psychotic

Disorders, Substance Induced Psychotic Disorder, Oppositional

Defiant Disorder, and Schizotypal Personality Disorder. The

psychologist diagnosed T. B. with Schizophreniform Disorder, in

Partial Remission, and concluded that T. B. understood the nature

of the proceedings and was capable of assisting his attorney with his

defense. Based on the competency evaluation, the juvenile court

found T. B. competent to proceed.

Prior to the adjudication hearing, T. B. filed a notice of intent

to offer a defense of insanity or delusional compulsion and moved

the juvenile court to order a forensic psychological evaluation to

determine whether he was incapable of appreciating the

wrongfulness of his acts when the incident occurred. During a

hearing on the matter, T. B.’s counsel acknowledged that the

Juvenile Code did not specifically address whether insanity and

delusional-compulsion defenses were available in delinquency

4 proceedings. Relying in part on constitutional principles of due

process and equal protection, however, counsel argued that T. B.

should be permitted to assert such a defense.2 The juvenile court

rejected T. B.’s arguments and ruled that insanity and delusional-

compulsion defenses are unavailable in juvenile-court proceedings.

The court reasoned that insanity is irrelevant in a delinquency

proceeding because an insanity defense seeks to establish that a

defendant is not “guilty,” and delinquency proceedings do not

adjudicate “guilt.” The court further reasoned that the Juvenile

Code does not expressly provide for an insanity defense, even though

it refers to an alibi defense, and that children do not have a

constitutional right to raise an insanity defense in delinquency

proceedings. Accordingly, the court prohibited T. B. from asserting

such defenses and denied his request for a forensic evaluation.3

2 T. B.’s counsel initially argued that the court should allow T. B. to “plead not guilty by reason of insanity.” When the court noted that juvenile courts “[do not] recognize guilty pleas,” however, T. B.’s counsel stated that T. B. was seeking to “deny the charges based on an insanity [defense].” 3 After the juvenile court granted T. B. a certificate of immediate review,

T. B. filed an application for interlocutory appeal with the Court of Appeals.

5 2. As a general matter, delinquency proceedings operate in a

The Court of Appeals granted that application, and T. B. filed a notice of appeal.

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