In the Interest of A.V., 48 A.3d 1251

A.V. was adjudicated delinquent for possessing an instrument of crime (PIC).
The dispositional order placed A.V. in boot camp for 60 days with motion to review for longer disposition.
A.V. had been on formal probation with house arrest and a 7:00 p.m. curfew.
A.V. violated house arrest by being outside after school, prompting investigation by probation and Steelton police.
Officers found counterfeit $20 bills on A.V.; closer inspection revealed the bills were counterfeit.
The trial court held the counterfeit bills constituted instruments of crime and intended criminal use; on appeal the court vacated the adjudication and disposition.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the evidence suffices to sustain PIC with criminal intent	AV: insufficient to prove intent	Commonwealth: intent may be inferred from circumstances	Insufficient evidence of intent; adjudication reversed

In re M.J.H., 988 A.2d 694 (Pa. Super. 2010) (standard for sufficiency after adjudication of delinquency; review of entire record)
Commonwealth v. Andrews, 564 Pa. 321, 768 A.2d 309 (Pa. 2001) (criminal purpose is touchstone; inferred from circumstances)
Commonwealth v. Hardick, 475 Pa. 475, 380 A.2d 1235 (Pa. 1977) (mere possession alone not enough to prove intent)
Commonwealth v. Foster, 438 Pa. Super. 40, 651 A.2d 163 (Pa. Super. 1994) (intent may be inferred but not from mere possession)
In re A.C., 763 A.2d 889 (Pa. Super. 2000) (mere possession of a weapon cannot prove criminal intent)