In the Interest of: A.A., a Minor
In the Interest of: A.A., a Minor No. 1217 EDA 2016
| Pa. Super. Ct. | Jun 6, 2017Background
- At a high-school pep rally, teacher Mary Matzo supervised from bleachers; students below rushed toward the floor near end of event.
- A.A. pushed Matzo from behind on the bleachers; Matzo fell down steps and suffered neck, back, knee, and hip pain and missed work.
- After the fall, Matzo accused A.A.; A.A. approached, used profane language, refused to give her student ID, and punched Matzo in the shoulder when Matzo tried to pull the ID loose.
- Juvenile court adjudicated A.A. delinquent of aggravated assault (18 Pa.C.S. §2702(a)(3)), simple assault, and disorderly conduct; A.A. moved for reconsideration and appealed the dispositional order.
- A.A. conceded recklessness (simple assault) but argued evidence was insufficient to prove the higher mens rea (intentional/knowing) required for aggravated assault upon a protected person performing duties.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether circumstantial evidence was sufficient to prove A.A. intentionally or knowingly caused bodily injury to a protected person (aggravated assault under §2702(a)(3)) | Commonwealth: conduct on the gym floor (refusal, profanity, punch) plus the bleacher shove supports an inference of intent to cause or prevent interference, and the bleacher fall resulted in bodily injury | A.A.: initial shove was reckless/accidental in a crowd; the floor punch was a single hit to stop pain from Matzo pulling a lanyard and did not show intent to cause bodily injury; at most summary harassment | Affirmed: Viewing evidence in Commonwealth's favor, court found sufficient circumstantial evidence of intent and that the bleacher fall produced bodily injury supporting aggravated assault |
Key Cases Cited
- In Interest of J.G., 145 A.3d 1179 (Pa. Super. 2016) (standard for sufficiency review in juvenile delinquency adjudication)
- Commonwealth v. Rahman, 75 A.3d 497 (Pa. Super. 2013) (comparison of §2701 and §2702 mens rea and application)
- Commonwealth v. Marti, 779 A.2d 1177 (Pa. Super. 2001) (interpretation of aggravated vs. simple assault bodily injury component)
- Commonwealth v. Richardson, 636 A.2d 1195 (Pa. Super. 1994) (intent may be inferred from conduct despite asserted emotional motivation)
- Commonwealth v. Matthews, 870 A.2d 924 (Pa. Super. 2006) (intent can be proven by circumstantial evidence and attendant circumstances)