Com. v. R.A.S., Com. v. R.A.S. No. 1100 MDA 2016

Appellant R.A.S. was convicted after a nonjury trial of rape of a child, IDSI, unlawful contact with a minor, indecent assault, two counts of EWOC, three counts of COM, and simple assault; sentenced July 21, 2015 after a SVP determination.
Appellant filed post-sentence motions and timely appealed; the court ordered a Rule 1925(b) statement identifying sufficiency issues.
The alleged victim J.M.P. was 13 at trial but abuse began when he was 6; the abuse involved Appellant as stepfather with repeated sexual and physical violence; witnesses D.T.M. and R.A.S. testified to corroborating abuse.
The Betty Nelson address (2010–2012) and subsequent residence moves established that acts occurred both before and after the 2010 COM statute amendment.
Appellant argued insufficiency of the evidence for several convictions; the Commonwealth asserted sufficient proof; the Superior Court found waiver due to failure to specify elements in the 1925(b) statement but also reviewed merits and concluded sufficiency supported the convictions.
The court affirmed the judgment of sentence, concluding sufficient evidence supported each challenged conviction, including COM as to R.A.S. based on corroborating testimony and conduct tending to corrupt morals.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Is the evidence sufficient to support the rape, IDSI, unlawful contact, indecent assault, and COM convictions for J.M.P.?	Garland sufficiency failure; the testimony varied and lacked corroboration; no proof beyond reasonable doubt for sexual offenses.	Evidence insufficient to sustain guilt on multiple sexual offenses against J.M.P.	Waived for lack of specificity; nevertheless judgments supported by the record.
Is the COM conviction as to R.A.S. supported by substantial evidence?	J.M.P. testimony alone does not prove conduct tending to corrupt morals toward R.A.S.	Testimony shows conduct affecting multiple children; sufficient to prove corruption of morals.	Yes; evidence sufficient to sustain COM as to R.A.S.

Commonwealth v. Garland, 63 A.3d 339 (Pa. Super. 2013) (sufficiency standard and need for specificity in Rule 1925)
Commonwealth v. Leatherby, 116 A.3d 73 (Pa. Super. 2015) (weight vs. sufficiency; evidence sufficiency under habitual abuse patterns)
Commonwealth v. Slocum, 86 A.3d 272 (Pa. Super. 2014) (scope of COM—conduct tending to corrupt morals)
Commonwealth v. Mumma, 414 A.2d 1026 (Pa. 1980) (corruption of morals standard broad protective statute)
Commonwealth v. DeWalt, 752 A.2d 915 (Pa. Super. 2000) (guidance on applying COM to diverse conduct)
Commonwealth v. Gibbs, 981 A.2d 274 (Pa. Super. 2009) (waiver where elements not specified in 1925(b) statement)