Com. v. Beaumont, J., Com. v. Beaumont, J. No. 1649 MDA 2016

Appellant Justin Beaumont sexually abused his stepdaughter over ~Oct 2014–Oct 2015; the victim disclosed the abuse in Nov 2015. Beaumont later gave a voluntary statement confessing and was arrested and charged with multiple sex-related offenses.
On June 6, 2016 Beaumont entered an open guilty plea to corruption of minors and disorderly conduct; remaining charges were to be dismissed by the Commonwealth.
The court deferred sentencing for a presentence investigation (PSI) and on Sept. 1, 2016 sentenced Beaumont to 18–36 months’ incarceration for corruption of minors (above the aggravated guideline range) plus 1 year probation consecutively for disorderly conduct.
The court explained the upward departure by citing the gravity of the offense, Beaumont’s minimization/blaming of the victim (failure to accept responsibility), the impact on the victim, and Beaumont’s need for sex-offender and mental-health treatment.
Beaumont filed post-sentence motion and timely appeal, arguing the sentence was excessive and that the court treated him as if he had a prior record score greater than zero and failed to consider mitigating factors (lack of prior record, steady employment, provider status, expression of remorse).
The Superior Court affirmed, holding the record (including the PSI and the court’s on-the-record reasons) showed the court considered relevant factors and did not abuse its sentencing discretion.

Issue	Appellant's Argument	Commonwealth/Trial Court Argument	Held
Whether the above‑aggravated sentence was excessive/abuse of discretion	Beaumont: court failed to consider mitigating factors (no prior record, employment, provider role, remorse) and misread his hospital statement as lack of remorse, producing an excessive sentence	Court: PSI was available; court considered gravity, victim impact, defendant’s minimization/blaming, and rehabilitation needs — reasons support upward sentence	Affirmed — no abuse of discretion; record shows court considered factors and reasonably imposed above‑aggravated sentence

Commonwealth v. Lutes, 793 A.2d 949 (Pa. Super. 2002) (discretionary-aspects-of-sentencing principles)
Commonwealth v. Sierra, 752 A.2d 910 (Pa. Super. 2000) (discretionary sentencing is not appealable as of right)
Commonwealth v. Evans, 901 A.2d 528 (Pa. Super. 2006) (four-part test for discretionary-sentencing review prerequisites)
Commonwealth v. Tirado, 870 A.2d 362 (Pa. Super. 2005) (open pleas preserve right to challenge discretionary aspects of sentence)
Commonwealth v. Mouzon, 812 A.2d 617 (Pa. 2002) (Pa.R.A.P. 2119(f) requirement and substantial-question standard)
Commonwealth v. Phillips, 946 A.2d 103 (Pa. Super. 2008) (limiting sentencing challenges to exceptional cases)
Commonwealth v. Anderson, 830 A.2d 1013 (Pa. Super. 2003) (what raises a substantial question)
Commonwealth v. Hyland, 875 A.2d 1175 (Pa. Super. 2005) (aggravated sentence without consideration of mitigating factors raises a substantial question)
Commonwealth v. Rodda, 723 A.2d 212 (Pa. Super. 1999) (abuse-of-discretion standard for sentencing review)
Commonwealth v. Crump, 995 A.2d 1280 (Pa. Super. 2010) (court need not deliver lengthy explanation; record as whole must show consideration of factors)
Commonwealth v. Griffin, 804 A.2d 1 (Pa. Super. 2002) (factors sentencing court should consider: prior record, age, personal characteristics, rehabilitative needs)