In Re: T.P., a minor, Appeal of: T.P., 632 WDA 2017

Appellant (juvenile, age 15) was adjudicated delinquent for conspiracy to possess heroin and possession of marijuana after police pursued a stolen silver Ford Explorer involved in a high‑speed chase and collision.
Police responded to a report after a firearm had been pointed at a male at a high school; the reported vehicle matched a stolen vehicle.
Officers located the stolen Explorer with four occupants; the Explorer ran a red light, struck another vehicle, and stopped; Appellant (front-seat passenger) tried to flee and was arrested.
Marijuana and heroin were recovered from occupants and inside the stolen vehicle.
Juvenile court ordered Appellant to pay $1,769.36 restitution for damage to the two vehicles and the stolen Ford; Appellant moved for reconsideration arguing no causal connection between his adjudicated drug-related acts and the vehicle damages.
The court denied reconsideration; Appellant appealed alleging (1) restitution lacked causal connection to his offenses and (2) the court abused its discretion by not considering juvenile‑specific factors.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether restitution requires a direct causal nexus between the juvenile's adjudicated acts and the victim's property damage	Appellant: restitution unlawful because his admitted drug‑related actions did not cause vehicle damages	Commonwealth/Juvenile Ct: restitution may address direct and indirect harms as rehabilitative accountability under § 6352	Court: No direct nexus required; restitution permissible as rehabilitative condition analogous to probation (In re M.W.)
Whether imposition of restitution was an abuse of discretion given juvenile's circumstances	Appellant: court failed to give proper weight to juvenile factors and erred in imposing restitution	Juvenile Ct: considered appellant’s participation, knowledge, prior record, and earning capacity; restitution is proportional and rehabilitative	Court: No abuse of discretion; juvenile court adequately explained basis and amount

In re M.W., 725 A.2d 729 (Pa. 1999) (juvenile restitution may be imposed like probation conditions; direct causal nexus relaxed to serve rehabilitative purposes)
In Interest of Dublinski, 695 A.2d 827 (Pa. Super. 1997) (pre‑M.W. holding requiring link between juvenile conduct and damages—overruled/limited by In re M.W.)
Commonwealth v. K.M.-F., 117 A.3d 346 (Pa. Super. 2015) (standard of review: juvenile dispositional orders reviewed for abuse of discretion)
In the Interest of A.D., 771 A.2d 45 (Pa. Super. 2001) (discussing juvenile court dispositional discretion)