U.S. v. Woods

Dist. Ct did not err in granting govt.’s motion to transfer to adult court multiple offenses relating to two armed robberies allegedly committed by defendant when he was 15 years old, but was almost 21 years old at time of instant motion. Charged offenses alleged that: (1) defendant was getaway driver in first armed robbery in which one customer was shot and another customer was grazed by bullet and participated in second armed robbery in which defendant had shot store clerk; and (2) defendant participated in said charged offenses with three other gang members. While Dist. Ct. could properly continue to exercise juvenile jurisdiction even though defendant became 21 during instant proceedings, Dist. Ct. also properly found that transfer to adult court was appropriate under factors set forth in section 5032 of Juvenile Delinquency and Protection Act, where: (1) defendant’s age meant that any juvenile-rehabilitation program would not be of much benefit; (2) instant charged offenses were serious in nature; (3) defendant had extensive juvenile criminal record involving 30 separate incidents; and (4) defendant had responded poorly in past treatment programs.