In the Interest of D.S., 39 A.3d 968

D.S. was adjudicated delinquent for providing false identification to law enforcement under 18 Pa.C.S.A. § 4914 after plainclothes officers stopped him near a school during an armed-robbery investigation.
Officers did not identify themselves as police or state they were investigating a violation when they questioned D.S. and obtained his information.
D.S. argued that liability under § 4914 required false information given after being informed of an official investigation by a uniformed or identified officer, and disputed the authenticity of a mother’s printout showing alias D.B.
The juvenile court adjudicated D.S. delinquent; the Superior Court affirmed, relying on the totality of circumstances to find D.S. knew he was talking to officers and thus violated § 4914.
This Court granted review to decide whether § 4914 requires affirmative police identification and notice of investigation as a condition to convict for false identification.
The majority held that the statute requires three express conditions: officer in uniform or identified as officer, informing the individual of an official investigation, and the provision of false information after being informed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does § 4914 require officer identification and notice of investigation?	D.S. argues no; knowledge may come from surrounding circumstances.	Commonwealth argues knowledge can be inferred from circumstances and that the statute is ambiguous.	Yes; three explicit conditions required
Can a juvenile challenge sufficiency of evidence for the first time on appeal?	D.S. raised sufficiency on appeal; should be reviewable de novo.	Waiver or procedural rules may bar first-time sufficiency claims.	Sufficiency challenge reviewable in first instance; not waived
Was the evidence sufficient to convict under § 4914 without officer identification/notice?	Totality of circumstances showed D.S. knew they were officers and subject of investigation.	No evidence officers identified themselves or informed him prior to statements.	Evidence insufficient; reverse Superior Court

In the Interest of Becker, 370 Pa.Super. 487 (1988) (recognizes criminal-rule-like appellate review for juveniles)
Commonwealth v. Hart, 28 A.3d 898 (Pa. 2011) (standard of review for sufficiency de novo; evidentiary inferences)
In the Interest of Thomas, 533 Pa. 572 (1993) (juvenile right to appeal governed by appellate rules)
In the Interest of McDonough, 287 Pa.Super. 326 (1981) (right to appeal for juveniles under the Juvenile Act)
Barnes, 14 A.3d 128 (Pa. Super. 2011) (statutory interpretation of § 4914 about when 'informed' matters)