Com. v. I.J.-W., 2018 MDA 2015

Appellant (I. J.-W.), age 14 at the time, participated in an assault at a juvenile residential program in which staff member Angel Wright was blindfolded, repeatedly struck, locked in a closet, and the offenders stole Wright’s vehicle; Appellant removed staff keys and assisted in the escape.
Commonwealth sought transfer of the juvenile case to adult criminal court; a certification hearing was held October 7, 2015.
Testimony and records showed Appellant’s extensive prior foster-care placements, history of aggressive behavior, prior delinquency (theft-related), and prior juvenile services; probation and social-work witnesses testified Appellant was not amenable to juvenile treatment.
The juvenile court certified the case to adult court under 42 Pa.C.S.A. § 6355 and Appellant pleaded guilty to criminal conspiracy to commit robbery on April 4, 2016; she was sentenced to time served to 23 months, plus one year probation.
Appellant appealed the certification decision, arguing (1) insufficient prima facie evidence for aggravated assault and (2) the Commonwealth failed to show the public interest supported transfer and that she was not amenable to juvenile rehabilitation.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Commonwealth established a prima facie case of aggravated assault to support transfer	Commonwealth: victim ID, facts showed probable cause Appellant was main actor and intended to cause serious bodily injury	Appellant: victim could not reliably identify attacker; injuries weren’t "serious bodily injury"	Court: Held prima facie case established—victim’s identification and circumstances warranted probable cause of intent to cause serious bodily injury
Whether transfer served the public interest and whether juvenile was amenable to treatment	Commonwealth: evidence of sophisticated attack, victim’s long-term psychological harm, Appellant’s treatment history and prior delinquency showed public interest favored transfer and lack of amenability	Appellant: impact was short-term, community harm minimal, she was the youngest of four and amenable to juvenile treatment	Court: Held juvenile court did not abuse discretion; record supported weighing of statutory public-interest factors and finding of non-amenability

Commonwealth v. Jackson, 722 A.2d 1030 (Pa. 1999) (standard of appellate review for juvenile certification decisions)
Commonwealth v. Hendricks, 927 A.2d 289 (Pa. Super. 2007) (definition of prima facie case for transfer)
Commonwealth v. Martuscelli, 54 A.3d 940 (Pa. Super. 2012) (intent and attempt analysis for aggravated assault)
Commonwealth v. Saez, 925 A.2d 776 (Pa. Super. 2007) (deference to juvenile court’s credibility and factor balancing)
In the Interest of McCord, 664 A.2d 1046 (Pa. Super. 1995) (interlocutory nature of transfer orders)