## Facts

- In 1985, Anderson, age 16, allegedly struck another teenager in the head with a baseball bat during a playground fight in Philadelphia.
- He was arrested and charged in the Family Court Division with aggravated assault, simple assault, recklessly endangering another person, possession of a weapon, and possession of an instrument of crime.
- Anderson failed to appear for the juvenile hearing, and the Family Court Division issued a bench warrant.
- In 1988, at age 19, Anderson allegedly committed retail theft, failed to appear, and the Philadelphia Municipal Court issued a separate bench warrant.
- In 1991, at age 22, Anderson was arrested on new, unrelated charges; the Commonwealth sought to prosecute him as an adult for the 1985 offenses.
- The Family Court Division lifted the juvenile bench warrant and transferred the 1985 case to the Trial Division because Anderson was no longer a “child” under Pennsylvania law.
- Anderson moved to dismiss in the Trial Division, arguing lack of subject-matter jurisdiction; the Trial Division ultimately dismissed the case, and the Commonwealth appealed.

## Issues

1. Whether the Trial Division of the Court of Common Pleas lacked subject-matter jurisdiction to prosecute, as an adult, a defendant for offenses allegedly committed when he was a juvenile.
2. Whether the internal allocation of matters between the Family Court Division and Trial Division limits the Court of Common Pleas’ jurisdiction so that only the Family Court Division may hear such cases.

## Decision

- The Superior Court reversed the Trial Division’s dismissal order.
- The court held the Court of Common Pleas had subject-matter jurisdiction over the prosecution, and the Trial Division could exercise that jurisdiction.
- The court ruled that the Family Court Division and Trial Division are administrative units within a single court, not separate courts with distinct subject-matter jurisdiction.
- The case was remanded to the Trial Division for further proceedings.

## Legal Principles

- The Court of Common Pleas has general, unlimited original jurisdiction conferred by the Pennsylvania Constitution and statute.
- Under 42 Pa.C.S. § 952, each division of the Court of Common Pleas is vested with the full jurisdiction of the whole court.
- Divisional assignment (Family Court Division versus Trial Division) concerns internal administration and case allocation, not subject-matter jurisdiction.
- A misassignment between divisions does not justify dismissal for lack of subject-matter jurisdiction where the Court of Common Pleas has authority over the subject matter and venue is proper.

## Conclusion

The Superior Court concluded that the Trial Division could prosecute Anderson for the 1985 offenses because divisions of the Court of Common Pleas share the court’s full subject-matter jurisdiction; the lower court’s dismissal treated an administrative allocation issue as a jurisdictional defect.


Commonwealth v. Anderson, 630 A.2d 47 (Pa. Super. Ct. 1993)