Commonwealth v. Slocum
86 A.3d 272
| Pa. Super. Ct. | 2014Background
- Slocum, a Catholic priest in Lewis Run, formed an intimate relationship with a minor neighbor, J.H., providing a teen-oriented pool room and expensive gifts.
- J.H. spent significant time at the rectory; the mother learned of lies and growing involvement, including overnight stays.
- Appellant admitted to creating the pool room to win the friendship of neighborhood youth and provided electronic gifts and money for chores.
- Mother grounded J.H. for skipping school and demanded no contact with Appellant; she informed Appellant by letter to keep J.H. away.
- J.H. continued contact via Appellant’s computers and Facebook, contrary to Mother’s instructions, prompting further contact with authorities.
- Police obtained a search warrant; Appellant gave a recorded statement admitting concealment of J.H.’s whereabouts from Mother and an inappropriate relationship.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Concealment of the whereabouts of a child sufficiency | Commonwealth: evidence showed concealment by not returning J.H. | Slocum: no removal or concealment from residence or parent | Sufficient evidence supported concealment conviction |
| Corruption of minors sufficiency | Commonwealth: conduct tended to corrupt morals under 6301(a)(1)(i) | Slocum: no underlying delinquent/criminal act required | Sufficient evidence supported corruption of minors conviction |
Key Cases Cited
- Commonwealth v. Mumma, 489 Pa. 547, 414 A.2d 1026 (Pa. 1980) ( affirmation that 'tends to corrupt' suffices; no need for actual corruption)
- Commonwealth v. Decker, 698 A.2d 99 (Pa. Super. 1997) (no predicate criminal act required for corruption of minors; broadly construed)
- Commonwealth v. DeWalt, 752 A.2d 915 (Pa. Super. 2000) (corruption of minors covers broad conduct; must tend to corrupt morals)
- Commonwealth v. Barnette, 760 A.2d 1166 (Pa. Super. 2000) (corruption of minors includes varied conduct protective of minors)
- Commonwealth v. Pankraz, 382 Pa. Super. 116, 554 A.2d 974 (Pa. Super. 1989) (illustrates broad interpretation of 'any act')
- Commonwealth v. Randall, 183 Pa. Super. 603, 133 A.2d 276 (Pa. Super. 1957) (early framework for corruption of minors analysis)