In the Interest of: A.J.J., a Minor
In the Interest of: A.J.J., a Minor No. 183 MDA 2017
| Pa. Super. Ct. | Sep 6, 2017Background
- Appellant A.J.J., a high‑school student, and victim K.R. dated and had mostly consensual sexual contact from April–August 2015.
- K.R. testified to two separate nonconsensual vaginal penetrations by A.J.J. at her home in July and August 2015; each incident occurred while others were in the house and lasted about 10–20 minutes.
- A petition alleging two counts of aggravated indecent assault (18 Pa.C.S. § 3125(a)(1)) was filed; adjudicatory hearing held September 9, 2016, where K.R. and A.J.J. both testified.
- The juvenile court found A.J.J. delinquent on both counts and placed him on probation at disposition (January 13, 2017).
- On appeal, A.J.J. challenged (1) sufficiency of the evidence and (2) weight of the evidence; he preserved the weight claim by raising it in his Rule 1925(b) statement.
- The Superior Court adopted the juvenile court’s opinion, affirmed the adjudication, and rejected both sufficiency and weight challenges.
Issues
| Issue | Plaintiff's Argument (Commonwealth) | Defendant's Argument (A.J.J.) | Held |
|---|---|---|---|
| Sufficiency: Whether evidence proved aggravated indecent assault beyond a reasonable doubt | K.R.’s testimony alone established nonconsensual penetration and lack of any legitimate purpose, satisfying every element | K.R.’s testimony was unreliable; relationship context and lack of corroboration defeat sufficiency | Affirmed — victim’s testimony alone was sufficient to sustain the adjudication |
| Weight: Whether the adjudication was against the weight of the evidence | Credibility determination in favor of K.R. was supported by the record; no basis to disturb the factfinder | Court improperly credited K.R.; delay in reporting, ongoing relationship, and lack of physical corroboration make verdict shocking | Affirmed — no abuse of discretion; verdict did not shock the court’s sense of justice |
Key Cases Cited
- Armbruster v. Horowitz, 813 A.2d 698 (Pa. 2002) (weight‑of‑evidence claims are addressed to the trial judge's discretion)
- Edwards, 903 A.2d 1139 (Pa. 2006) (standard for reviewing weight claims)
- Blakeney, 946 A.2d 645 (Pa. 2008) (appellate role is not to reweigh evidence on weight review)
- Widmer, 689 A.2d 211 (Pa. 1997) (preservation and framing of weight claims)
- Karkaria, 625 A.2d 1167 (Pa. 1993) (weight is for the trial court to resolve)
- Clay, 64 A.3d 1049 (Pa. 2013) (new trial warranted only when verdict shocks one’s sense of justice)
- Lyons, 79 A.3d 1053 (Pa. 2013) (distinguishing sufficiency from weight claims)
- McElrath, 592 A.2d 740 (Pa. 1991) (weight principles apply in juvenile proceedings)
- In re J.B., 106 A.3d 76 (Pa. 2014) (procedural preservation of weight claims in juvenile cases)
- In re J.M., 89 A.3d 688 (Pa. Super. 2014) (sufficiency standard for juvenile adjudications)
- In re T.O.C., 836 A.2d 1003 (Pa. Super. 2003) (sufficiency standard applied to juvenile cases)
- In re H., 648 A.2d 28 (Pa. Super. 1994) (victim’s testimony alone can support a sexual‑assault conviction)
