In the Interest of: R.C., a Minor, 2335 EDA 2012

In December 2011, then-13-year-old R.C. admitted in Delaware County juvenile court to criminal mischief and conspiracy for breaking 30 windows at a nursing home and agreed to restitution of $1,528.36 (with credit for amounts already paid or performed).
The Delaware County court accepted the admission, included the restitution amount in its adjudication order, and transferred disposition to Philadelphia County where R.C. lived.
R.C. later sought clarification in Philadelphia, arguing he should only be liable for one-third ($509.45) based on an alleged joint-and-several allocation among three juveniles. He did not challenge the propriety of restitution itself.
Philadelphia Juvenile Court Judge Reynolds denied R.C.’s petition and treated the restitution as a settled term of the Delaware adjudication, not a new dispositional order.
R.C. filed a timely post-dispositional motion and appealed the denial, arguing the court imposed an indeterminate restitution amount and failed to apportion liability among co-defendants.
The Superior Court affirmed, holding R.C. was bound by the agreed-upon restitution in the Delaware adjudication and that Philadelphia could not (and should not) alter a coordinate judge’s order absent exceptional circumstances.

Issue	Appellant's Argument	Respondent's Argument	Held
Whether Philadelphia court erred by enforcing an allegedly indeterminate restitution award	R.C.: restitution was indeterminate or improperly imposed as joint-and-several; he should only owe one-third	Commonwealth/Transferee court: restitution was a determinate $1,528.36 set in Delaware adjudication; credit applies	Held: No error — adjudication specified $1,528.36; R.C. bound by that amount
Whether transferee court could revisit or apportion restitution imposed by transferring court	R.C.: transferee should determine and apportion amount among juveniles	Judge Reynolds/Commonwealth: doctrine of coordinate jurisdiction prevents overruling a coequal judge absent exceptional circumstances	Held: Transferee properly declined to modify prior adjudication under coordinate-jurisdiction rule
Whether R.C. preserved challenges to the validity of restitution or Delaware court's authority	R.C.: (on appeal) implicitly challenges propriety/authority	Commonwealth: R.C. failed to contest restitution below and accepted it as part of his admission, so such claims are waived	Held: Challenges to restitution’s propriety or court authority are waived for failure to raise below
Whether exceptional circumstances justified departing from prior adjudication	R.C.: did not identify changed law/facts or clear error	Commonwealth: no intervening change, no manifest injustice; parties bargained for restitution	Held: No exceptional circumstances; prior order stands

K.H. v. J.R., 826 A.2d 863 (Pa. 2003) (interlocutory orders subsumed by final judgment in single action).
In re M.D., 839 A.2d 1116 (Pa. Super. 2003) (dispositional order triggers right of appeal in juvenile cases).
In re Love, 646 A.2d 1233 (Pa. Super. 1994) (standard of review and deference to juvenile court dispositions).
Commonwealth v. Starr, 664 A.2d 1326 (Pa. 1995) (coordinate-jurisdiction rule and limited exceptions to departing from a coequal judge’s decision).
Commonwealth v. Weigle, 997 A.2d 306 (Pa. 2010) (application of coordinate-jurisdiction principles).
Commonwealth v. Holder, 805 A.2d 499 (Pa. 2002) (coordinate-jurisdiction discussion).
Steiner v. Markel, 968 A.2d 1253 (Pa. 2009) (waiver of issues not raised below; limits of Rule 1925(b)).
Commonwealth v. Melendez-Negron, 123 A.3d 1087 (Pa. Super. 2015) (parties entitled to benefit of plea/admission bargains).
In re A.M., 766 A.2d 1263 (Pa. Super. 2000) (juvenile admission is equivalent to a guilty plea).