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Commonwealth v. Cotto

562 Pa. 32, 753 A.2d 217 (2000)

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Commonwealth v. Cotto

Pennsylvania Supreme Court

562 Pa. 32, 753 A.2d 217 (2000)

Facts

Pennsylvania had a direct-file statute that caused certain crimes, including any crime committed with a deadly weapon, to be filed directly in adult criminal court if the defendant was 15 years old or older. However, the state also had a reverse-certification statute that allowed criminal courts to certify a minor as a juvenile and transfer the case to juvenile court if the minor could show that transferring the case would serve the public interest. The reverse-certification statute identified a list of factors that the criminal court should consider in order to determine whether a transfer would serve the public interest. Under the direct-file statute, charges against 15-year-old Abraham Cotto (defendant) for armed robbery were filed in criminal court. Under the reverse-certification statute, Cotto moved to be certified as a juvenile and to have his case transferred to juvenile court. The criminal court considered the statutory factors and denied Cotto’s transfer request. Cotto pleaded guilty and appealed only the order denying transfer, arguing that the reverse-certification statute was unconstitutional because (1) the serve-the-public-interest standard was vague and (2) putting the burden on a minor to justify a transfer to juvenile court violated a minor’s due-process rights.

Rule of Law

Issue

Holding and Reasoning (Castille, J.)

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