In the Interest of: J.F., Appeal of: J.F.

Superior Court of Pennsylvania·Decided August 12, 2026·No. 75 WDM 2026·Unpublished·Olson

Opinion

NON-PRECEDENTIAL DECISION - SEE SUPERIOR COURT O.P. 65.37

IN THE INTEREST OF: J.F., A MINOR : IN THE SUPERIOR COURT OF : PENNSYLVANIA

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APPEAL OF: J.F. :

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: No. 75 WDM 2026

Appeal from the Order Entered June 30, 2026 In the Court of Common Pleas of Allegheny County Juvenile Division at No(s): CP-02-JV-0000212-2026

BEFORE: OLSON, J., NICHOLS, J., and LANE, J. MEMORANDUM BY OLSON, J.: FILED: August 12, 2026 Petitioner, J.F., filed a petition for specialized review of his out-of-home placement, in accordance with Pennsylvania Rule of Appellate Procedure 1612,1 and challenges the juvenile court’s dispositional order of June 30, 2026, which committed Petitioner to out-of-home placement. Based upon our deferential standard of review, we affirm.

Petitioner is a 14-year-old boy who, following a colloquy at an adjudicatory hearing on June 29, 2026, admitted to and was adjudicated delinquent for acts constituting possession of a firearm by a minor and

1 As our Supreme Court has held: “the expedited review provided for by [] Rule 1612 is afforded to juvenile petitioners as of right. The Superior Court lacks the discretion to decide whether to grant or deny these petitions for specialized review.” Interest of N.E.M., 311 A.3d 1088, 1101 (Pa. 2024).

harassment.2 Pursuant to the negotiated plea agreement, the Commonwealth withdrew three additional counts (firearms not to be carried without a license, recklessly endangering another person, and simple assault)3 and also withdrew a second delinquency petition alleging theft by unlawful taking, firearms not to be carried without a license, and possession of a firearm by a minor.4 The juvenile court held a dispositional hearing on the same date. The Commonwealth presented testimony from Petitioner’s probation officer, Charles Bloomer. Before testifying, Mr. Bloomer addressed the court in a preliminary statement. He noted that this was Petitioner’s first formal juvenile court involvement but expressed concern that Petitioner’s firearm-related charges, combined with “a pattern of behavior under community supervision,” raised significant questions about whether Petitioner could be safely managed in the community. N.T. Hearing, 6/29/26, at 7. Despite this concern, Mr. Bloomer acknowledged several encouraging indicators: Petitioner had demonstrated recent academic improvement, raising failing grades to passing grades; he had not missed a single day of school since the last hearing, with only one tardy; and his psychological evaluation described him as generally

prosocial, capable of insight, and likely to benefit from structured, skill-based

2 18 Pa.C.S.A. §§ 6110.1(a) and 2709(a)(7), respectively.

3 See 18 Pa.C.S.A. §§ 6106(a)(1), 2705, and 2701(a)(3), respectively.

4 See 18 Pa.C.S.A. §§ 3921(a), 6106(a)(1), and 6110.1, respectively.

intervention. Id. at 7-8. Notwithstanding those positives, Mr. Bloomer stated that these strengths had “not yet translated” into a position where the probation office believed it was in Petitioner’s best interest to remain in the community and, therefore, he recommended commitment to an out-of-home placement — specifically George Junior or Summit Academy — citing Petitioner’s family circumstances, which he characterized as marked by “severe parent/child conflict and permissive environment at the father’s domicile.” Id. at 8.

On direct examination, Mr. Bloomer confirmed that Petitioner had been on electronic home monitoring (“EHM”) since the prior hearing and had not incurred a single violation or monitor shutdown. Id. at 9. He agreed this represented a “marked improvement” over Petitioner’s earlier period of EHM. Id. Mr. Bloomer confirmed Petitioner’s improvement in school attendance and grades since the prior court date, consistent with his preliminary statement. Id. Mr. Bloomer also confirmed that he had referred Petitioner’s family to Human Services Administration Operation (“HSAO”), but they did not follow up with the referral; instead, Petitioner appeared to be enrolled in therapy through his school, although HSAO had reached out and conducted an intake conference with him. Id. at 10. Mr. Bloomer confirmed that, if Petitioner were to remain in the community, probation would recommend his participation in the Community Intensive Supervision Program (“CISP”). Id. He described CISP as an added level of community supervision that limits Petitioner’s unsupervised time in the community while still permitting him to

return home after school or daily programming. Id. at 10. He explained that CISP provides transportation to appointments and school-related activities, and offers programming that includes an “impact of crime curriculum” and gun violence prevention components. Id. at 10-11. Mr. Bloomer further testified that Petitioner’s psychological evaluation did not recommend a residential treatment facility, and that his mental health concerns could be addressed through outpatient treatment. Id. at 11-12. Finally, when asked about additional recommended probation conditions, Mr. Bloomer indicated that, aside from out-of-home placement, his recommendations were: payment of all associated court costs and fees; a no-contact provision with the victim (though he noted uncertainty as to whether that remained applicable given the amended delinquency petition); and compliance with mental health treatment. Id. at 12. The Commonwealth did not conduct cross-examination.

Petitioner’s counsel presented two witnesses. First, Derrick Chaffin, a loan officer/coordinator with HSAO, testified on direct examination that he had been working with Petitioner since the HSAO referral was made. Id. at 14. At the time of the hearing, he met with Petitioner once in person and had a second meeting was scheduled for the following day. Id. He had also been in contact with Petitioner’s mother. Id. Mr. Chaffin testified that he discussed a treatment plan with Petitioner during their initial intake meeting. Id. At that meeting, Petitioner’s mother provided insurance information, and Mr. Chaffin assisted the family in identifying therapy resources. Id. Specifically,

he identified a therapy provider located approximately eight minutes from the family’s home, at which Petitioner’s mother was already a patient. Id. Mr. Chaffin testified that the provider indicated Petitioner could be seen concurrently with his mother’s appointments. Id. Mr. Chaffin also noted that Petitioner appeared to be receiving some form of therapy through his school, though he acknowledged uncertainty as to the precise format — describing it as potentially a virtual or telephone-based service. Id. at 14-15. Mr. Chaffin testified that, based on his conversations with Petitioner and Petitioner’s mother, Petitioner appeared willing and interested in participating in mental health treatment. Id. at 15. Finally, Mr. Chaffin confirmed that he had not personally received a copy of Petitioner’s mental health evaluation. Id. The Commonwealth did not conduct cross-examination.

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In the Interest of: J.F., Appeal of: J.F., (Pa. Ct. App. 2026).

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