A recent case decided by the Commonwealth Court of Pennsylvania, G.V. v. Department of Public Welfare, 125 C.D. 2011 (Pa.Cmwlth. 2012), has profoundly changed the burden of proof necessary to have someone listed on the ChildLine and Abuse Registry (ChildLine) as a perpetrator of child abuse.
In the above-referenced case, G.V. was accused of abusing his 16-year-old great-niece C.S. The alleged abuse was reported to Children and Youth Services (CYS), which conducted an investigation resulting in a finding of “indicated.” Per the finding of “indicated,” CYS went forward and filed a report with ChildLine that G.V. is a child abuser. G.V., disagreeing with CYS’s aforesaid report, timely requested a hearing. G.V. lost the appeal. G.V. then appealed to the Commonwealth Court arguing that CYS did not meet an appropriate burden of proof in order to rule against him.
