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In the Interest of J.M.
89 A.3d 688
| Pa. Super. Ct. | 2014
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Background

  • 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)
Read the full case

Case Details

Case Name: In the Interest of J.M.
Court Name: Superior Court of Pennsylvania
Date Published: Apr 7, 2014
Citation: 89 A.3d 688
Court Abbreviation: Pa. Super. Ct.