Commonwealth v. McKee

BECK, Judge,

concurring and dissenting:

While I agree with the majority’s determination that Appellant’s case could properly be transferred under Section 6355 of the Juvenile Act (“Act”), 42 Pa.C.S. § 6355, to an “adult” court, I disagree with the majority’s view that Appellant’s constitutional right to a fair trial as an “adult” was adequately protected in this instance where the trial court took judicial notice of the factual findings of the *17transfer hearing judge and incorporated same into its evaluation of Appellant’s guilt.

A transfer hearing pursuant to the Act does not possess all the safeguards of an “adult” court trial. Although the Act does guarantee, inter alia, the right to counsel (42 Pa.C.S. § 6337), the right to cross-examine witnesses (42 Pa.C.S. § 6338),1 and the right against self-incrimination (42 Pa.C.S. § 6338), the Act specifically denies the right to a jury. “Hearings under the [Act] shall be conducted by the court without a jury, in an informal but orderly manner .... ” Section 6336 of the Act, 42 Pa.C.S. § 6336 (emphasis added). See McKeiver v. Pennsylvania, 403 U.S. 528, 91 S.Ct. 1976, 29 L.Ed.2d 647 (1971); Commonwealth v. McNaughton, 252 Pa.Super.Ct. 302, 381 A.2d 929 (1977). The purpose of the hearing is for the Commonwealth to make a prima facie case not prove all the elements of the crime beyond a reasonable doubt. Additionally, the defendant at a prima facie hearing does not expect to develop fully whatever defense he may have.

Moreover, the purpose and scope of a transfer hearing differ markedly from those of a criminal court trial. Whereas a criminal court trial addresses the merits of both the Commonwealth’s and the accused’s positions, Section 6355(a) of the Act states that “[a]fter a petition has been filed alleging delinquency based on conduct which is designated a crime . . ., the court before hearing the petition on its merits may rule that [the Act] is not applicable .. . and transfer the offense ... to ... a judge of the court assigned to conduct criminal proceedings . . . . ” (Emphasis added.) A transfer must be supported by, inter alia, a finding “that there is a prima facie case that the child committed the delinquent act alleged.” 42 Pa.C.S. § 6355(a)(4)(i) (emphasis added).2

*18The transfer hearing did not offer Appellant the opportunity to trial by jury. The standard of proof of the crime at the transfer hearing was not beyond a reasonable doubt but was limited to the establishment of a prima facie case. I therefore would hold that the trial court’s adoption of the factual findings of the transfer hearing judge denied Appellant his basic constitutional right to a fair trial including his right to a jury trial and to proof of guilt beyond a reasonable doubt.

I would accordingly reverse and remand for a new trial not inconsistent with this view.

. Juveniles also have the right to confront their accusers. McKeiver v. Pennsylvania, 403 U.S. 528, 91 S.Ct. 1976, 29 L.Ed.2d 647 (1971).

. Although Section 6341 of the Act, 42 Pa.C.S. § 6341, provides that a finding of delinquency must be based “on proof beyond a reasonable doubt that the child committed the acts by reason of which he is *18alleged to be delinquent,” Section 6355 which governs transfers to “adult” court, does not contain a similar prerequisite for a finding of inapplicability of the Juvenile Act but merely requires proof of a prima facie case in order to effectuate a transfer to “adult” court.