## Facts

- Abraham Martinez Cotto was 15 years old when he participated in two armed robberies in Lancaster, Pennsylvania.
- On April 23, 1996, Cotto and two accomplices, armed with a handgun, robbed individuals at a beauty salon.
- On May 8, 1996, Cotto and three accomplices, again armed with a handgun, robbed a jewelry store and individuals present.
- Cotto was charged in adult criminal court with multiple counts of robbery and criminal conspiracy arising from both incidents.
- Adult-court filing was based on amendments to Pennsylvania’s Juvenile Act excluding certain offenses (including robbery with a deadly weapon) committed by juveniles age 15 or older from the definition of a “delinquent act.”
- Cotto moved for transfer to juvenile court under the reverse-transfer provision and also sought habeas relief, arguing the amendments were unconstitutional.
- After a transfer hearing, the trial court denied transfer and rejected the constitutional challenges; Cotto entered a guilty plea in adult court while preserving the transfer ruling for appeal.
- The Superior Court affirmed, and the Pennsylvania Supreme Court granted review to address federal and state due process challenges.

## Issues

1. Whether the reverse-transfer standard permitting transfer to juvenile court when it would “serve the public interest” is unconstitutionally vague under the Fourteenth Amendment and Article I, Section 9 of the Pennsylvania Constitution.
2. Whether due process is violated by placing on the juvenile the burden to prove that transfer to juvenile court would serve the public interest.

## Decision

- The Pennsylvania Supreme Court affirmed the Superior Court and upheld the 1995 Juvenile Act amendments.
- The Court held the “serve the public interest” standard was not void for vagueness when read with the statute’s enumerated factors guiding the transfer decision.
- The Court held it was constitutional to place the burden of proof on the juvenile seeking reverse-transfer to juvenile court.
- The denial of transfer remained in effect, leaving Cotto’s adult-court convictions intact.

## Legal Principles

- A statutory standard is not unconstitutionally vague when the statute, read as a whole, supplies sufficient guidance to direct judicial decision-making and constrain discretion.
- In reverse-transfer determinations, a “public interest” standard may satisfy due process when the legislature requires consideration of specific factors such as offense seriousness, the juvenile’s age and maturity, victim impact, prior record, and amenability to treatment and rehabilitation.
- The legislature may assign original criminal-court jurisdiction for specified serious offenses committed by older juveniles involving deadly weapons by excluding those offenses from the definition of “delinquent act.”
- There is no fundamental constitutional right to be tried in juvenile court; juvenile treatment is a statutory benefit subject to legislative conditions.
- Allocating to the juvenile the burden of proving eligibility for reverse-transfer is consistent with due process where the legislature makes reverse-transfer an exception and procedural safeguards (hearing, factor-based analysis, and appellate review) are provided.

## Conclusion

The court upheld Pennsylvania’s direct-file and reverse-transfer scheme for certain serious juvenile offenses, ruling that the “public interest” transfer standard is sufficiently defined by statutory factors and that placing the burden on the juvenile to justify transfer to juvenile court does not violate federal or state due process.


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