State v. M. A. S., 462 P.3d 284

Youth (13) was charged by delinquency petition with first-degree sodomy and coercion for forcing a 13‑year‑old girlfriend to perform oral sex; the petition sought appropriate juvenile orders.
On the morning of the two‑day jurisdictional hearing, the state moved to amend the petition to add one count of second‑degree sexual abuse (Sex Abuse II); defense objected but declined a continuance.
The juvenile court allowed the amendment without making contemporaneous written findings required by ORS 419C.261(1) and proceeded; after hearing, the court asserted jurisdiction solely on the Sex Abuse II allegation and entered a signed minute order.
At the dispositional hearing months later the state presented restitution evidence (therapist costs) and the court ordered $6,900 in restitution; youth objected that restitution evidence was untimely under ORS 419C.450.
Youth appealed arguing (1) the court lacked authority to amend without written findings and that the amendment on the morning of trial violated due process notice, and (2) restitution evidence was presented too late; the Court of Appeals affirmed on the amendment/notice claims but reversed the restitution award and remanded for a new dispositional judgment.

Issue	Plaintiff's Argument (Youth)	Defendant's Argument (State)	Held
Authority to amend petition without written findings under ORS 419C.261(1)	Court lacked authority to amend and thus to adjudicate because it failed to make mandatory written findings when adding a sex‑crime allegation	Youth failed to preserve the claim; case law (C.N.W.) does not strip jurisdiction for lack of findings	Rejected youth’s claim; court did not lose authority and judgment adjudicating on Sex Abuse II stands
Due process notice for morning‑of hearing amendment	Amendment that occurred the morning of trial denied adequate notice; court should have offered a continuance	Youth expressly declined a continuance at the hearing; no preservation of any separate due‑process rule	Rejected: no due‑process violation because youth declined postponement and thus had adequate notice
Timing for presenting restitution evidence under ORS 419C.450	"Prior to or at the time of adjudication" means before or at close of adjudicatory hearing; restitution presented at disposition was untimely	"Adjudication" continues until a judgment is entered; restitution was timely when presented before the adjudication judgment	Agreed with youth: adjudication occurred at the close of the jurisdictional hearing; restitution evidence was untimely. Restitution award reversed and matter remanded for new dispositional judgment

State v. Bucholz, 317 Or. 309 (Or. 1993) (preservation principle: request for findings required to preserve certain challenges)
State ex rel Juvenile Dept. v. C. N. W., 212 Or. App. 551 (Or. Ct. App. 2007) (statute requiring mandatory written findings must be complied with; remedied by vacatur/remand for findings)
State ex rel Juvenile Dept. v. J. J., 228 Or. App. 746 (Or. Ct. App. 2009) (failure to make statutorily required findings may be plain error; remand for findings)
State v. Barrett, 350 Or. 390 (Or. 2011) (explains adjudication vs. disposition distinction in juvenile cases)
State ex rel Juvenile Dept. v. Tyree, 177 Or. App. 187 (Or. Ct. App. 2001) (juvenile adjudications and dispositions may be effected by orders even if labeled judgments)
State v. Ramos, 358 Or. 581 (Or. 2016) (context on statutory amendments making restitution mandatory)