Philadelphia DHS v. DHS

CourtCommonwealth Court of Pennsylvania
DecidedOctober 17, 2025
Docket671 C.D. 2024
StatusUnpublished

This text of Philadelphia DHS v. DHS (Philadelphia DHS v. DHS) is published on Counsel Stack Legal Research, covering Commonwealth Court of Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Philadelphia DHS v. DHS, (Pa. Ct. App. 2025).

Opinion

IN THE COMMONWEALTH COURT OF PENNSYLVANIA

Philadelphia County Department : SEALED CASE of Human Services, : Petitioner : : v. : : Department of Human Services, : No. 671 C.D. 2024 Respondent : Submitted: July 7, 2025

BEFORE: HONORABLE ANNE E. COVEY, Judge HONORABLE LORI A. DUMAS, Judge HONORABLE BONNIE BRIGANCE LEADBETTER, Senior Judge

OPINION NOT REPORTED

MEMORANDUM OPINION BY JUDGE COVEY FILED: October 17, 2025

The Philadelphia County Department of Human Services (DHS) petitions this Court for review of the Department of Human Services (Department), Bureau of Hearings and Appeals’ (BHA) April 29, 2024 order adopting the Administrative Law Judge’s (ALJ) Recommendation that sustained M.S.-G.’s request to amend her child abuse report on the ChildLine and Abuse Registry (ChildLine)1 from founded to indicated.2 Essentially, DHS presents one issue for this Court’s review: whether the BHA erred by concluding that DHS did not satisfy its burden of proof and, as a result, recommended that DHS and the Department amend the status of M.S.-G.’s child abuse report to an indicated status.3 After review, this Court affirms.

1 Section 3490.4 of the Department’s Regulations defines ChildLine as [a]n organizational unit of the Department which operates a [s]tatewide toll-free system for receiving reports of suspected child abuse established under [S]ection 6332 of the [Child Protective Services Law [(CPSL)], 23 Pa.C.S. § 6332] (relating to establishment of [s]tatewide toll-free telephone number), refers the reports for investigation and maintains the reports in the appropriate file. 55 Pa. Code § 3490.4. 2 A founded report is defined in Section 3490.4 of the Department’s Regulations as [a] child abuse report made under the CPSL and this chapter if there has been any judicial adjudication based on a finding that a child who is a subject of the report has been abused, including the entry of a plea of guilty or nolo contenderee [sic] or a finding of guilt to a criminal charge involving the same factual circumstances involved in the allegation of child abuse. 55 Pa. Code § 3490.4 An indicated report is defined therein as [a] child abuse report made under the CPSL and this chapter if an investigation by the county agency or the Department determines that substantial evidence of the alleged abuse exists based on any of the following: (i) Available medical evidence. (ii) The child protective service investigation. (iii) An admission of the acts of abuse by the perpetrator. Id. 3 In its Statement of Questions Presented, DHS presented three issues for this Court’s review: (1) whether the BHA erred by issuing an adjudication that lacks the findings necessary to support the adjudication in accordance with Section 507 of the Administrative Agency Law, 2 Pa.C.S. § 507; (2) whether the BHA impermissibly reviewed the Protection from Abuse (PFA) order for error when it considered whether the PFA Judge was aware of unidentified discrepancies in the witness’ statements in the various proceedings; and (3) whether the BHA incorrectly found

2 On September 15, 2022, DHS received a referral report of child abuse against M.S.-G., child’s mother. On October 24, 2022, DHS filed an indicated report of child abuse against M.S.-G. On November 1, 2022, ChildLine informed M.S.-G. that her name would be listed as a perpetrator on an indicated report of child abuse. On November 10, 2022, ChildLine received M.S.-G.’s request for a hearing to expunge the indicated report. The BHA held a hearing on April 5, 2023. On June 22, 2023, before the BHA ruled on the expunction, a Protection from Abuse (PFA) judge (PFA Judge) entered a PFA order against M.S.-G. stating:

The evidence is not sufficient for me to enter an order of protection on either side;[4] so, I’m going to vacate the temporary orders and the petition[s] will be dismissed. Regarding the petition filed on behalf of [the child], the concern is really just the September 15th incident. There were other concerning behaviors, but what happened during that incident was very distressing, inappropriate. The child was put at risk and he was injured. So, I am going to enter an order on his behalf. It’s an order for protection only. That does not prohibit you from seeing your child.

that the PFA order did not involve the same factual circumstances where the final PFA order was predicated on the same incident and abuse as the allegations of abuse in the founded report and the trial court found that the abuse occurred. See DHS Br. at 4. These issues are subsumed in the issue as rephrased by this Court and will be addressed accordingly. 4 The PFA Judge conducted a hearing on three PFA petitions: The first was filed by [father, G.G.] against [M.S.-G.]. A temporary full order was put into place on September 2[nd] of 2022. The second was filed by [G.G.,] on behalf of [child, L.G.], date of birth October 14[th] of 2021, against [M.S.-G.] A temporary full order was put into place on September 16[th] of 2022, and that order was modified on January 17[th] of 2023. The third petition was filed by [M.S.-G.] against [G.G]. A temporary full order was put into place on September 16th of 2022. Reproduced Record at 66a (emphasis added).

3 It just says that he can’t be harmed. That order is going to be in place for one year. It’s also going to specify that no one shall smoke marijuana around this child under any circumstances, regardless of location.

Reproduced Record (R.R.) at 59a (emphasis added). On June 27, 2023, DHS informed the BHA that it had filed a CY-495 to change the status of the child abuse report from indicated to founded based upon a final PFA order involving M.S.-G. and the subject child, L.G. On August 15, 2023, the BHA received a founded CY-486 for M.S.-G. regarding the allegation of child abuse, from which M.S.-G. appealed at the April 5, 2023 hearing. On August 24, 2023, the BHA mailed a Hearing Scheduling Order to the parties, scheduling a hearing before an ALJ on M.S.-G.’s appeal for October 23, 2023. After multiple continuances, the BHA held an administrative hearing on February 8, 2024. Thereafter, the ALJ issued a recommendation that the Department amend M.S.-G.’s report of child abuse from founded to indicated. The ALJ explained:

While the court documentation submitted by DHS details the allegations of child abuse involving [M.S.-G.] and the subject child, [L.G.,] there are discrepancies in the testimony of the subject child’s father[, G.G.,] and [the] nanny [(Nanny)] that was given at the April 5, 2023[] hearing on the indicated report and at the June 20 and 21, 2023 PFA hearing. It should be noted that these discrepancies in the testimonies of [G.G.] and [N]anny were not brought up at the June 20 and 21, 2023 hearing dates. There were also statements made by [G.G.] in his [p]etition for a PFA that are significantly different than his testimony at the April 5, 2023[] hearing on the indicated report. . . . In order to sustain a founded report, a [PFA] adjudication [must] find[] that the child abuse occurred. In this matter, the June 21, 2023 PFA transcript shows that the [PFA] Judge [] granted the PFA noting that, “regarding

5 A CY-49 is the child protective services supplemental report. See R.R. at 12a-14a. 6 A CY-48 is the child protective services investigation report. See R.R. at 20a-22a. 4 the petition filed on behalf of L.G., the concern is just the September 15th incident. There were other concerning behaviors, but what happened during that incident was very distressing, very inappropriate. [L.G.] was put at risk and he was injured. So I’m going to grant an order on his behalf.” While DHS makes the argument that the language of [the PFA] Judge [] in this order meets the [sic] [PFA] adjudication finds that the child abuse occurred requirement under [Section 6303 of the [CPSL], 23 Pa.C.S.

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Bluebook (online)
Philadelphia DHS v. DHS, Counsel Stack Legal Research, https://law.counselstack.com/opinion/philadelphia-dhs-v-dhs-pacommwct-2025.