Com. v. Bryant, R., 2226 EDA 2015

Victim AB alleged two sexual assaults by Richard Bryant (her aunt’s then-paramour) when she was about 6–8; incidents involved digital penetration and partial penile penetration. She did not disclose at the time.
In 2004 a CHOP exam showed genital irritation and a hymenal notch; no criminal investigation resulted because AB would not identify a perpetrator then.
In March 2012, at age 14, AB disclosed the abuse to her mother during a mental-health crisis; DHS later classified the 2012 report as unfounded for current safety risk.
Appellant was arrested in April 2012 and tried in January–February 2015; the jury convicted him of rape of a child and related offenses and the court sentenced him to 17–34 years’ imprisonment. SORNA lifetime registration applies.
On appeal, Bryant challenged (1) sufficiency of the evidence and (2) the trial court’s restriction on cross-examining the victim’s mother about alleged motive to fabricate; the Superior Court affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of the evidence to support convictions	Commonwealth: AB’s testimony, medical records, DHS and police reports supported convictions	Bryant: Victim’s delayed disclosure, inconsistencies, lack of contemporaneous reporting and physical corroboration made verdict speculative	Affirmed — uncorroborated victim testimony, if believed, is sufficient; inconsistencies about age/timing did not render testimony inherently unreliable
Exclusion of cross-examination of victim’s mother about father’s incarceration (motive to fabricate)	Bryant: Mother’s relationship with father and timing provided motive to fabricate and jury should hear it	Commonwealth: Objections sustained; trial court limited questioning as improper without a proper offer of proof	Affirmed — issue waived for appellate review because defense failed to make an offer of proof or preserve the record explaining relevance

Commonwealth v. Kakaria, 625 A.2d 1167 (Pa. 1993) (verdict cannot rest on mere surmise or conjecture when evidence is inherently unreliable)
Commonwealth v. Farquharson, 354 A.2d 545 (Pa. 1976) (jury verdict must not be based on evidence so lacking it is pure conjecture)
Commonwealth v. Davis, 650 A.2d 452 (Pa. Super. 1994) (uncontradicted testimony of sexual assault victim can be sufficient to convict if believed)
Commonwealth v. Groff, 548 A.2d 1237 (Pa. Super. 1988) (child victims are allowed some imprecision about dates and times when testifying)