IN THE INTEREST OF M. F., A CHILD.
granted certiorari in this case to address whether the Court
of Appeals erred in dismissing as moot the appeal of a
juvenile delinquency adjudication.
11, 2017, the juvenile court of Richmond County entered an
order of disposition finding M. F. delinquent for criminal
attempt to enter an automobile and placing M. F. on probation
for 12 months. On May 31, 2017, M. F. filed his notice of
appeal, and his case was docketed in the Court of Appeals on
October 23, 2017. On appeal, M. F. argued that the evidence
was insufficient to support the juvenile court's
adjudication of delinquency. On May 11, 2018, M. F.'s
probationary sentence concluded, and, on May 22, 2018, the
Court of Appeals issued an order in which it declined to
reach the merits of M. F.'s appeal, concluding that his
case was moot because his probationary sentence had expired
and because M. F. "has not shown, on this record, any
adverse collateral consequences arising from the juvenile
court's adjudication of him as delinquent." For the
reasons set forth below, we reverse the order of the Court of
Appeals and remand the case for further proceedings.
is an issue of jurisdiction and thus must be determined
before a court addresses the merits of a claim."
(Citation omitted.) Shelley v. Town of Tyrone, 302
Ga. 297, 308 (3) (806 S.E.2d 535) (2017). When the resolution
of a case would be tantamount to "the determination of
an abstract question not arising upon existing facts or
rights," then that case is moot. Collins v. Lombard
Corp., 270 Ga. 120, 121 (1) (508 S.E.2d 653) (1998); see
also Jayko v. State, 335 Ga.App. 684, 685 (782
S.E.2d 788) (2016) ("When the remedy sought in
litigation no longer benefits the party seeking it, the case
is moot and must be dismissed." (citation and
punctuation omitted)). Dismissal of moot cases is mandatory.
See Collins, 270 Ga. at 121 (1).
we have recognized circumstances where cases that may appear
to be moot are nonetheless viable due to the particular
nature of the litigated issue. Specifically, in the criminal
context, apparent mootness can be defeated where
"adverse collateral consequences continue to plague the
affected party." (Citation omitted.) In the Interest
of I. S., 278 Ga. 859, 862 (607 S.E.2d 546) (2005).
Where a party challenges the legality of his conviction after
his sentence has expired, collateral consequences are
presumed if the party was convicted of a felony. See
Atkins v. Hopper, 234 Ga. 330, 333 (2) (216 S.E.2d
89) (1975). On the other hand, a party convicted of a
misdemeanor is required to demonstrate, in the record,
adverse collateral consequences that have continued beyond
the expiration of his sentence to show that his case is not
moot. Abebe v. State, 304 Ga. 614, 615 (820 S.E.2d
678) (2018). Of course, M. F. was convicted of neither a
felony nor a misdemeanor because his adjudication of
delinquency is not a criminal conviction. See OCGA §
State urges this Court to treat adjudications of juvenile
delinquency as it treats misdemeanor convictions and to
require that a juvenile appealing his adjudication of
delinquency demonstrate collateral consequences in the
record. In support of its position, the State points to OCGA
§ 15-11-606, which provides that "[a]n order of
disposition or adjudication shall not be a conviction of a
crime and shall not impose any civil disability ordinarily
resulting from a conviction." But this argument ignores
other consequences flowing from an adjudication of
delinquency. Simply because a juvenile who has been
adjudicated delinquent may later be able to vote, serve on a
jury, lawfully possess a firearm, and say that he has not
been convicted of a crime does not negate the fact that
significant adverse collateral consequences inherently and
unquestionably can flow from the adjudication.
held in In the Interest of M. D. H., 300 Ga. 46, 48
n.2 (793 S.E.2d 49) (2016), an adjudication of delinquency
"could affect [a juvenile] in later juvenile or criminal
proceedings." See also In the Interest of B.
L., 333 Ga.App. 860, 861 n.7 (777 S.E.2d 705) (2015).
For instance, juvenile courts are permitted to consider prior
delinquency adjudications during sentencing. See OCGA §
15-11-601 (a) (directing a juvenile court to consider, among
other things, the prior record of a child adjudicated
delinquent when entering its disposition order). Prior
adjudications permit a juvenile court to treat a delinquent
act as eligible for designated-felony status, even where the
delinquent act would not ordinarily be treated as such. See
OCGA §§ 15-11-2 (12) (K), (L); 15-11-2 (13) (K),
(O). Further, the Juvenile Code specifically provides that
"the disposition of a child and evidence adduced in a
hearing in the juvenile court" may be used against the
child "in the establishment of conditions of bail, plea
negotiations, and sentencing in criminal offenses." OCGA
§ 15-11-703. Similarly, the federal sentencing
guidelines treat prior juvenile adjudications as aggravating
factors for calculating a defendant's sentence in federal
court. See United States Sentencing Commission Guidelines
Manual § 4A1.2 (d) (2). And juvenile records, while
closed to inspection by the general public, are available to
various parties for a wide range of purposes. See OCGA
§§ 15-11-703; 15-11-708.
the consequences of a juvenile's adjudication of
delinquency continue to reverberate even after the expiration
of his disposition.  See M. D. H., 300 Ga. at 48, n.2.
Accordingly, we hold that a juvenile who appeals his
adjudication of delinquency is not required to show adverse
collateral consequences in the record; such consequences will
be presumed. 
on the foregoing, the Court of Appeals erred, and we reverse
its order and remand this case for consideration on the
reversed, and case remanded.
 Because we conclude the consequences
discussed herein are sufficiently tangible and adverse to
provide a presumption to juvenile defendants, we do not
attempt to address the full list of consequences suggested by
M. F. on ...