Com. v. Klingensmith, A.

CourtSuperior Court of Pennsylvania
DecidedJanuary 23, 2026
Docket99 WDA 2025
StatusUnpublished
AuthorStabile

This text of Com. v. Klingensmith, A. (Com. v. Klingensmith, A.) is published on Counsel Stack Legal Research, covering Superior Court of Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Com. v. Klingensmith, A., (Pa. Ct. App. 2026).

Opinion

J-A19024-25

NON-PRECEDENTIAL DECISION - SEE SUPERIOR COURT O.P. 65.37

COMMONWEALTH OF PENNSYLVANIA : IN THE SUPERIOR COURT OF : PENNSYLVANIA Appellant : : : v. : : : AARON JOHN KLINGENSMITH : No. 99 WDA 2025

Appeal from the Order Entered January 23, 2025 In the Court of Common Pleas of Clearfield County Criminal Division at No: CP-17-CR-0000473-2024

BEFORE: BOWES, J., STABILE, J., and BENDER, P.J.E.

MEMORANDUM BY STABILE, J.: FILED: January 23, 2026

In this interlocutory appeal, the Commonwealth seeks review of an order

transferring a criminal case to the Clearfield County Juvenile Division.

Appellee, Aaron John Klingensmith, is alleged to have fatally shot a 12-year-

old victim when he was 14 years old. The Commonwealth charged Appellee

as an adult with several felony counts, including the non-delinquent act of

criminal homicide (18 Pa.C.S.A. § 2501). Appellee petitioned to have the case

decertified and transferred to the juvenile division. Appellee received a clinical

evaluation, and the trial court held a hearing on Appellee’s petition. The trial

court entered a transfer order over 20 days after the date of the hearing. The

Commonwealth now appeals that non-final order, contending that the trial

court abused its discretion by improperly considering statutorily mandated

factors that would weigh against a transfer. Finding no such error on the part

of the trial court, we affirm. J-A19024-25

The subject shooting allegedly took place on April 28, 2024. As averred

in the Commonwealth’s affidavit of probable cause, Appellee found a handgun

on top of his family’s gun safe located in the living room of his home. See

Affidavit of Probable Cause, 5/2/2024, at p.6. While sitting with the victim on

a couch in the living room, he asked the victim if she wanted to see the

weapon; as he did so, he discharged the weapon, striking the victim’s head

and causing fatal injuries. See id.

Moments before the weapon was fired, Appellee asked whether it was

loaded. See id. Appellee’s father initially explained to the police that it would

have been necessary for Appellee to chamber a round from the magazine in

order for the weapon to be fired. See id., at p.7. Appellee subsequently

stated in an interview with police that, without his parents’ knowledge, he had

previously handled the weapon and practiced chambering and unchambering

rounds. He told the police that he mistakenly believed there to be no round

in the gun’s chamber when he pulled the trigger. See Evidentiary Hearing,

11/25/2024, at 29.

The victim was pronounced dead on May 1, 2024. At the preliminary

hearing held on May 17, 2024, the Commonwealth charged Appellee as an

adult with one general count of criminal homicide (18 Pa.C.S.A. § 2501). This

count was in addition to the previously charged offenses of aggravated assault

causing serious bodily injury; aggravated assault causing bodily injury with a

deadly weapon; and recklessly endangering another person.

-2- J-A19024-25

Appellee received a psychiatric evaluation by Dr. Veronique Valliere on

August 11, 2024. Dr. Valliere opined in her report that Appellee did not act

with malice, that the shooting was accidental, that he did not pose a risk to

the public, and that he was amendable to treatment and rehabilitation. On

September 9, 2024, Appellee filed a petition to decertify the criminal

proceedings and transfer the case to the juvenile division. The trial court held

a hearing on the petition on November 25, 2024.

Appellee presented the testimony of Dr. Valliere, and the

Commonwealth relied solely on “the criminal complaint and affidavit of

probable cause, criminal information, preliminary hearing transcript and

recorded interview of the juvenile by the Pennsylvania State Police.” Trial

Court 1925(a) Opinion, 1/23/2025, at 2. At the conclusion of the evidentiary

hearing, the trial court granted Appellee’s petition, having determined that he

made a “compelling case for the transfer of this matter from the adult to the

juvenile division[.]” Id., at 3.

On January 23, 2005, as mandated by the Juvenile Act, the trial court

entered a transfer order in which it made several factual findings as to the

propriety of a transfer. The order closely tracked factors (A) through (G) of

42 Pa.C.S.A. § 6355(a)(4)(iii), which must be considered by a trial court when

ruling on a transfer petition:

1. The Court accepts Dr. Valliere as an expert in psychology.

2. The Court finds the Testimony of Dr. Valliere to be truthful, convincing, and controlling.

-3- J-A19024-25

3. The Court finds the clinical report of Dr. Valliere to be credible, convincing, and controlling.

4. The Court determines that [factor (A)] does not support the transfer of the case. The victim has paid with her life and her family and friends will suffer a lifetime.

5. The Court determines that [factor (B)] does not support transfer of the case. The foster parents, neighbors, and community will live with the trauma of seeing and experiencing the victim's death.

6. The Court determines that [factor (C)] supports transfer in that [Appellee] does not pose a threat to the safety of any individual or the public at large. "Diagnostically, [Appellee] does not meet criteria for any diagnosis that would be related to a future likelihood of violence." Valliere Report, p. 11.

7. The Court determines that [factor (D)], nature and circumstances, supports transfer because the actions of [Appellee] were not "intentional, planful, or likely to be repeated." Valliere Report, page 11.

8. The Court determines [that factor (E)] supports the transfer in that culpability is in the nature of an accident. "[Appellee] is a 14- year-old boy who committed an immature, impulsive act that resulted in his killing of his friend. The devastating nature of the crime is not mitigated by the fact that it appears to have been a tragic accident" however, culpability is mitigated.

"[Appellee] does not demonstrate any psychological or characterological issues that facilitated any malicious, intentional or retaliatory behavior. He does not demonstrate any characteristics that reveal cruelty, callousness, or obsession with killing, power, or death." Valliere Report, p. 9.

9. The Court determines that [factor (F)] supports the transfer. [Appellee] was a 14-year-old boy at the time of the offense. This means [Appellee] could be subject to the Juvenile Court's jurisdiction for up to seven years. (42 Pa.C.S.A. § 6302). The Court notes that the concerns raised in the report are not in the nature of his need for rehabilitation but his need for counseling to protect his mental health. Valliere Report, p. 9-11.

-4- J-A19024-25

10. The Court determines that [factor (G)] supports the transfer. [Appellee] is amenable to treatment and supervision through the Juvenile Division of the Court.

(I) [Appellee] was fourteen years old at the time of the offense.

(II) [Appellee] has average I.Q. functioning with Specific Learning Disability and ADHD. Valliere Report, p. 9.

(III) [Appellee’s] maturity is limited by his age and his ADHD. Valliere Report, p. 7.

(IV) There was no criminal sophistication involved.

(V) No prior criminal record exists.

(VI) No delinquency history.

(VII) See paragraph 9 above.

(Vlll) The most telling factor concerning [Appellee’s] institutional history is [that] this Court placed [Appellee] in a juvenile facility at the initiation of this case.

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Com. v. Klingensmith, A., Counsel Stack Legal Research, https://law.counselstack.com/opinion/com-v-klingensmith-a-pasuperct-2026.