The Superior Court has decided the case of In re: J.C., holding that a juvenile court does not have the jurisdiction to adjudicate a juvenile defendant delinquent for the offense of corruption of minors. The corruption of minors statute plainly applies only to someone who is over 18 years of age, and so a juvenile defendant may not be charged in juvenile court with a violation of this statute.

The facts of In re: J.C.

A police officer in Monroe County obtained an arrest warrant for J.C., alleging that J.C. had sexually assaulted a female classmate while the two were riding on a school bus. The school district deleted surveillance video of the incident during a software update, but the complainant reported the incident to school officials. The officials then questioned J.C., and J.C. admitted that he had done it. The Commonwealth then charged him in juvenile court with aggravated indecent assault, indecent assault, and open lewdness.

J.C. filed a motion to suppress the statement, arguing that school officials were required to give him Miranda warnings before questioning him. J.C. also moved to dismiss the case due to the school district’s destruction of the video evidence. The trial court denied the motion, and J.C. eventually entered into an admission (juvenile guilty plea) to the charge of corruption of minors. The court accepted the admission, and the Commonwealth agreed to nolle prosse the remaining charges. The court adjudicated J.C. delinquent. J.C. filed timely post-dispositional motions. The court denied the motions, and J.C. appealed. On appeal, J.C. argued both that the court should have granted his motions and that certain portions of his sentence were unconstitutional or illegal.

The Superior Court’s Ruling

 J.C. did not actually argue that the admission was illegal because corruption of minors could not apply to him, a minor. The Superior Court, however, has the authority to review cases for jurisdiction sua sponte, and in this case, the Court, on its own, recognized that the trial court did not have jurisdiction to accept the admission.

Corruption of minors is defined as follows:

(1) (i) Except as provided in subparagraph (ii), whoever, being of the age of 18 years and upwards, by any act corrupts or tends to corrupt the morals of any minor less than 18 years of age, or who aids, abets, entices or encourages any such minor in the commission of any crime, or who knowingly assists or encourages such minor in violating his or her parole or any order of court, commits a misdemeanor of the first degree.

18 Pa.C.S. § 6301(a)(1)(i)

The Court recognized that the statute, by its plain language, seeks to prevent prohibited actions between minors and individuals 18 years or older, otherwise defined as an adult. Here, J.C. was clearly not an adult – he was a minor at the time of the incident. Therefore, he could not be prosecuted for corruption of minors because the statute applies only to someone who is older than 18. There were other offenses he could have been prosecuted for, as he originally was, but it was illegal for the court to accept an admission to a charge which does not apply to juveniles. The court lost jurisdiction when the Commonwealth withdrew the properly filed charges and charged J.C. only with a charge that applies to adults.  

Therefore, the Superior Court reversed the disposition and remanded the case back to the juvenile court for further proceedings. It did not rule on whether the Commonwealth could reinstate the original charges. This ruling benefits J.C. in that it vacates his adjudication, but ultimately, it could make things worse for him as the Commonwealth may seek to proceed on the original, more serious sex offenses. Nonetheless, it is clear that a juvenile court may not hear a prosecution against a juvenile defendant for corruption of minors as that statute applies only to adults.

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