In the Interest of J.M.
89 A.3d 688
| Pa. Super. Ct. | 2014Background
- J.M., a minor, was adjudicated delinquent for sexual assault and aggravated indecent assault after a March 18, 2013 hearing.
- The offenses arose from a September 22, 2011 encounter with B.A. after being with M.L.; B.A. reported the encounter was not consensual.
- The juvenile court found Appellant committed the offenses and, on May 17, 2013, entered a dispositional order placing him on probation with conditions.
- Appellant filed a post-dispositional motion and a timely notice of appeal; the court issued a Rule 1925(a) opinion responding to a Rule 1925(b) statement.
- Appellant raises three issues on appeal: sufficiency of the evidence, weight of the evidence, and the impact of delay and SORNA registration requirements.
- The court ultimately affirms, holding Appellant must register as a juvenile offender under SORNA for life regardless of adjudication timing.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of the evidence to prove delinquency | Appellant asserts the Commonwealth failed to prove non-consent. | Commonwealth contends B.A.’s testimony supportively establishes lack of consent. | No relief; evidence supports delinquency beyond a reasonable doubt. |
| Weight of the evidence | Inconsistencies in B.A.’s testimony show the verdict is against the weight of the evidence. | The juvenile court acted within its discretion in weighing testimony; credibility determinations are for the court. | No relief; the court did not palpably abuse its discretion on weight claim. |
| Impact of delay and SORNA registration requirements | Adjudication timing post-SORNA could affect whether Appellant is a lifelong registrant. | Under SORNA, Appellant qualifies as a juvenile offender and must register for life, regardless of adjudication timing. | No relief; Appellant is a juvenile offender under SORNA and must register for life. |
Key Cases Cited
- In re T.G., 836 A.2d 1003 (Pa. Super. 2003) (defers to trial court credibility and evidence sufficiency standard)
- In re C.S., 63 A.3d 351 (Pa. Super. 2013) (weight-of-the-evidence review limited; court may not disturb unless palpable abuse of discretion)
