In the Int. of: K.L., Appeal of: N.L., 1868 EDA 2021

June 2019: five-week-old K.L. presented at St. Christopher's with a left, non-displaced skull fracture and extra-axial hemorrhage; admitted to PICU. DHS received a CPS report the same month.
Dr. Atkinson (SCHC Child Protection Unit) testified the injury was blunt-force trauma, could result from a short (3–4 ft) fall, and swelling might appear immediately or days later; the infant lacked mobility to self-inflict.
Mother told DHS the infant may have fallen on June 8, 2019 when her 10‑year‑old daughter tried to load the unsecured car seat into a tall pickup; Mother said she was on the opposite side of the truck and believed the child was buckled.
Mother delayed seeking medical care until swelling appeared four days later; her statements to the court and DHS were inconsistent and the trial court found her not credible.
Trial court adjudicated the child abused based on Mother’s reckless failure to supervise (allowing a 10‑year‑old to handle the infant and car seat), concluding the recklessness caused bodily injury; Mother appealed. Superior Court affirmed.

Issue	Plaintiff's Argument (Mother)	Defendant's Argument (DHS)	Held
Whether the trial court erred in finding child abuse under the CPSL	The injury was an accident; Mother acted reasonably and immediately cared for the child; she lacked intent to harm	Mother’s inconsistent statements and testimony show reckless failure to supervise that caused the skull fracture	Court affirmed: finding of child abuse upheld (reckless causation, not intentional harm)
Whether DHS proved abuse by clear and convincing evidence (i.e., injury was nonaccidental or caused by recklessness)	Medical testimony allows an accidental explanation; prior safe practice by daughter; lack of proof Mother intended harm	Medical and testimonial evidence established foreseeable risk from Mother’s choice to let a 10‑year‑old load the infant into a tall truck and inconsistent accounts undermine Mother’s credibility	Court held DHS met clear and convincing standard to show Mother acted recklessly and caused bodily injury

Interest of T.G., 208 A.3d 487 (Pa. Super. 2019) (standard of review in dependency appeals)
In re R.J.T., 9 A.3d 1179 (Pa. 2010) (deference to trial court credibility findings)
In Interest of J.M., 166 A.3d 408 (Pa. Super. 2017) (clear‑and‑convincing evidence standard in child‑abuse proceedings)
In re Novosielski, 992 A.2d 89 (Pa. 2010) (definition of clear and convincing evidence)
C.F. v. Pennsylvania Dep’t of Pub. Welfare, 804 A.2d 755 (Pa. Cmwlth. 2002) (prior‑statute authority finding accident where death ruled accidental)
Matter of Read, 693 A.2d 607 (Pa. Super. 1997) (prior version of statute and holding that inconsistent medical testimony precluded abuse finding)