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In the Interest of: R.S.A., a Minor
In the Interest of: R.S.A., a Minor No. 3114 EDA 2015
| Pa. Super. Ct. | Jun 2, 2017
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Background

  • Appellant R.S.A., age 13, was adjudicated delinquent for involuntary deviate sexual intercourse with a child (IDSI), sexual assault, and indecent assault based on allegations that he lured a 7‑year‑old victim into a bathroom at a child’s birthday party and put his penis in her mouth.
  • Victim identified Appellant at the adjudicatory hearing; the juvenile court found her testimony credible and consistent with prior statements to teacher, counselor, and mother.
  • The juvenile court placed Appellant on probation, ordered participation in an outpatient sex‑offender program (DelStar), drug screens, no unsupervised contact with children under 12, and a curfew.
  • On appeal, Appellant challenged (1) the sufficiency of the evidence supporting the delinquency adjudications and (2) that the adjudications were against the weight of the evidence.
  • The Superior Court affirmed sufficiency, agreeing the Commonwealth presented adequate, consistent testimony to sustain the adjudications.
  • Because Appellant did not file a post‑dispositional motion raising a weight claim, the Superior Court remanded to permit nunc pro tunc filing of such a motion, following juvenile‑procedure precedents addressing preservation of weight claims.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Sufficiency of the evidence to support adjudications Commonwealth: Victim’s consistent testimony and prior statements proved elements of IDSI, sexual assault, and indecent assault. Appellant: Evidence was unreliable and contradictory, insufficient to prove guilt beyond a reasonable doubt. Affirmed: Evidence was sufficient; victim credible and testimony consistent with prior statements.
Whether adjudications were against the weight of the evidence Commonwealth: Not directly argued below; relied on sufficiency and credibility findings. Appellant: Adjudications shock the conscience; trial court should reassess facts and grant new adjudication. Not resolved on merits: Remanded to juvenile court to allow Appellant to file a post‑dispositional motion nunc pro tunc to present the weight challenge.

Key Cases Cited

  • In re J.B., 106 A.3d 76 (Pa. 2014) (juvenile delinquency rules silence on preserving weight claims requires remand to allow post‑dispositional motion nunc pro tunc).
  • Interest of J.G., 145 A.3d 1179 (Pa. Super. 2016) (applies In re J.B.; declines to deem weight claim waived where juvenile first raised it in Rule 1925(b), remanding for post‑dispositional motion).
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Case Details

Case Name: In the Interest of: R.S.A., a Minor
Court Name: Superior Court of Pennsylvania
Date Published: Jun 2, 2017
Docket Number: In the Interest of: R.S.A., a Minor No. 3114 EDA 2015
Court Abbreviation: Pa. Super. Ct.