In the Int. of: I.E.C., a Minor
385 MDA 2024
| Pa. Super. Ct. | Jun 16, 2025Background
- I.E.C., a minor, was adjudicated delinquent for acts that would constitute involuntary deviate sexual intercourse (IDSI), sexual assault, and indecent assault against his younger cousins, if committed by an adult.
- The incidents occurred between January 2020 and August 2022; at the time of the hearing, I.E.C. was 14, the victims were 8 and 9.
- Abuse was not initially reported due to threats from I.E.C.; discovery of the acts led to law enforcement involvement and delinquency proceedings.
- Following hearings, the juvenile court found the children credible, found I.E.C. delinquent on multiple counts, and placed him on probation.
- I.E.C. appealed, challenging the sufficiency of the evidence, legal grading of offenses, and alleged ineffective assistance of counsel.
- The Superior Court affirmed the juvenile court’s order.
Issues
| Issue | Appellant’s Argument | Commonwealth’s Argument | Held |
|---|---|---|---|
| Sufficiency of evidence for each offense | Insufficient evidence of multiple instances and forcible compulsion | Testimony supports number of adjudications and element of compulsion | Evidence sufficient for all charges |
| Sufficiency re: forcible compulsion in IDSI/indecent assault | No proof of threat preventing resistance by reasonable person | Threats, age disparity, and credible testimony support compulsion | Forcible compulsion established |
| Proper grading of indecent assault counts | No evidence for felony enhancements on (a)(7) counts | Record shows course of conduct and touching of intimate parts | Felony grading appropriate |
| Ineffective assistance by not filing weight challenge | Counsel’s omission prejudiced appeal rights | No merit to weight claim; court found victims credible | No ineffectiveness; no prejudice shown |
Key Cases Cited
- Int. of J.C.N., 332 A.3d 1286 (Pa. Super. 2025) (sets standard for reviewing sufficiency of evidence in juvenile delinquency adjudications)
- Commonwealth v. Gonzalez, 109 A.3d 711 (Pa. Super. 2015) (defines and applies the concept of forcible compulsion)
- Int. of D.P., 233 A.3d 847 (Pa. Super. 2020) (discusses offense grading and sufficiency challenges in juvenile court)
- In re K.A.T., Jr., 69 A.3d 691 (Pa. Super. 2013) (lays out review of ineffective assistance claims in juvenile proceedings)