In the Interest of I.R.M., 2026 Pa. Super. LEXIS 414 (Pa. Super. Ct. 2026)

The Pennsylvania Superior Court vacated dispositional and adjudicatory orders because the trial court failed to conduct an evidentiary hearing on whether the youth was in need of treatment, supervision, or rehabilitation. The court stated in relevant part:

Here, the juvenile court did not conduct a hearing; rather, it proceeded directly to making a finding that I.R.M. was in need of treatment, rehabilitation, or supervision. See N.T. Adjudicatory Hearing, 12/3/25, at 6. Moreover, it is evident from the record that the juvenile court relied only upon I.R.M.’s admission to the misdemeanor offense of possession of controlled substance, which, by statute, cannot solely support a finding of need under the second prong of section 6341(b). See id.; see also M.W., 39 A.3d at 966 n.9 (presumption of need applies only to felony offenses and even though felonies “presumptively support[] a finding that the juvenile is in need of treatment and supervision . . . the juvenile court must still make that finding after allowing for other evidence“) (emphasis added). The juvenile court’s failure to adhere to the express language of section 6341(b), and our Supreme Court’s interpretation of that language in M.W., constitutes an error of law. See K.G., supra; M.W., supra.