Wednesday's Pennsylvania Superior Court decision in Commonwealth v. Krankowski (opinion by Judge Alice Beck Dubow, joined by Justices Maria McLaughlin & Daniel McCaffery) upheld a conviction for falsely reporting child abuse. Defendant had sent the principal and vice-principal at her son's high school an email linking to one of her Facebook posts, which alleged that a caseworker at the Snyder County Children and Youth Services Agency "subjected my son to physical and sexual abuse of his person and giggled/laughed about it. Later, Shambaugh was elevated to supervisor at Children and Youth." The recipients were "both mandated reporters, who proceeded to make a report of suspected child abuse to the Agency." Defendant had also made the same accusation in a call to the Agency. Defendant was found guilty, and sentenced "to two years' probation and, as a condition of probation, ordered … to submit to a mental health evaluation and follow all recommendations."
This, the court held, was a criminal false report even though it wasn't made directly to the police. The statute makes it a crime to "intentionally or knowingly make a false report of child abuse under 23 Pa.C.S. Ch. 63 (relating to child protective services)," and the court reasoned:
