In re Christian V.

California Court of Appeal Feb 24, 2026 No. D085820Published

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Holding. A juvenile delinquency case becomes final for purposes of Estrada retroactivity when the time to appeal the dispositional order has lapsed, and subsequent postjudgment orders do not render the case nonfinal.

Issues

Does the amendment to Welfare and Institutions Code section 730.6, subdivision (b)(3), apply retroactively to a juvenile whose dispositional order was final before the law's effective date?
Does a juvenile's case remain nonfinal for retroactivity purposes if the court retains jurisdiction over restitution or if the juvenile appeals subsequent postjudgment orders?

Disposition. Affirmed

Quotations verified verbatim against the opinion

“the appeal of a postjudgment order does not render the case nonfinal for purposes of Estrada because his dispositional order cannot be subsequently “ ‘ “ ‘attacked on an appeal from a later appealable order’ ” ’ ” or judgment.”

Filed 2/24/26 CERTIFIED FOR PUBLICATION

COURT OF APPEAL, FOURTH APPELLATE DISTRICT

DIVISION ONE

STATE OF CALIFORNIA

In re CHRISTIAN V., a Person Coming Under the Juvenile Court Law. D085820 THE PEOPLE,

Plaintiff and Respondent, (Super. Ct. No. J245910)

CHRISTIAN V.,

Defendant and Appellant.

APPEAL from orders of the Superior Court of San Diego County, Robert J. Trentacosta, Judge. Affirmed. John L. Staley, under appointment by the Court of Appeal, for Defendant and Appellant. Rob Bonta, Attorney General, Charles C. Ragland, Chief Assistant Attorney General, Ann M. Spitzberg and Stephanie H. Chow, Deputy Attorneys General, for Plaintiff and Respondent. The People filed a petition in the juvenile court alleging Christian V. (Minor) committed vandalism of property worth more than $400. (Pen. Code, § 594, subds. (a) & (b)(1).) Minor admitted the allegation was true. On

October 23, 2024, under the version of Welfare and Institutions Code 1 section 730.6 that was in effect at the time, the court ordered Minor to pay victim

restitution, making him jointly and severally liable with his parents 2 and co-offender. On January 1, 2025, the Legislature’s amendment to section 730.6, subdivision (b)(3), came into effect. (Stats. 2024, ch. 805 § 6, effective January 1, 2025.) The amendment removed the juvenile courts’ ability to order joint and several liability for victim restitution among co-offenders, instead requiring each minor to be held severally liable for a percentage of the victim restitution that equates to their percentage of fault. (Compare Stats. 2015, ch. 131, § 1, effective January 1, 2016, with Stats. 2024, ch. 805 § 6, effective January 1, 2025.) After the new law came into effect, Minor requested the juvenile court make him solely liable for one-half of the victim restitution. The court denied Minor’s request. Minor appeals the court’s orders and contends his case is not yet final and the newly enacted section applies retroactively. We requested the parties submit letter briefs addressing the finality of Minor’s case. After reviewing the parties’ briefs, we conclude Minor’s case became final before the new law came into effect and thus could not apply to Minor’s case. FACTUAL AND PROCEDURAL BACKGROUND At a disposition hearing on September 9, 2024, the juvenile court adjudged Minor a ward of court pursuant to section 602 and placed him on probation with various terms and conditions. The court reserved jurisdiction

In re Christian V.

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COURT OF APPEAL, FOURTH APPELLATE DISTRICT

DIVISION ONE

STATE OF CALIFORNIA

CHRISTIAN V.,

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