OCGA 15-11-63 Interpretation
In In the Interest of J.V., 282 Ga. App. 319, 320-322 (638 S.E.2d 757) (2006), the Court held that although OCGA 15-11-63 suggests that a juvenile court could order a child's early release from a youth development center to a less restrictive form of custody and that a child or the Department could move for early discharge from custody once a child is in custody, OCGA 15-11-40 (b) prohibits the change, modification, or vacation of a commitment order "on the ground that changed circumstances so require in the best interest of the child."
Compare In the Interest of B. D. T., 219 Ga. App. 804, 804-805 (466 S.E.2d 680) (1996) (juvenile court could modify its order of commitment when child had not yet been transferred to physical custody of Department). OCGA 15-11-40 (b), however, does not prohibit the change, modification, or vacation of a commitment order on other grounds. Interest of J.V., supra, 282 Ga. App. at 321.