Commonwealth v. Ruffin
10 A.3d 336
| Pa. Super. Ct. | 2010Background
- Ruffin was convicted by jury of conspiracy to commit armed robbery and sentenced to 4 to 10 years' imprisonment.
- Ruffin, then 18, sought transfer/decertification to juvenile court; the decertification court denied transfer.
- The trial court relied on § 6322(a) and § 6355(a)(4)(iii) factors to determine amenability to juvenile treatment.
- Ruffin had an extensive juvenile delinquency history with multiple programs and probation violations since 2003.
- The court found Ruffin previously unamenable to rehabilitation and concluded juvenile jurisdiction should not end at age 21.
- Ruffin challenged a police testimony from Sergeant Race about his non-cooperation; the court allowed the testimony and Ruffin appealed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether decertification was properly denied | Ruffin argued transfer would serve the public interest | Commonwealth argued he failed to prove amenability by preponderance | No abuse; transfer not warranted |
| Whether Sergeant Race testimony about non-cooperation was admissible | Ruffin claimed it violated ruling and his rights | Race testimony was within the court's side-bar ruling and remains admissible | Admissible; no abuse of discretion |
Key Cases Cited
- Commonwealth v. Ramos, 920 A.2d 1253 (Pa. Super. 2007) (abuse of discretion standard for decertification decisions)
- Commonwealth v. Aziz, 724 A.2d 371 (Pa. Super. 1999) (decertification transfer process and criteria)
- Commonwealth v. Jackson, 555 Pa. 37, 722 A.2d 1030 (1999) (extent of required explanation in certification decisions)