The juvenile court has discretion to deviate from an award of full victim restitution where compelling and extraordinary reasons exist, including where others are responsible. (WIC 730.6.) For restitution apportionment purposes, “co-offender” as used in includes only individuals who have been adjudicated as offenders, but the trial court has the duty to consider factors including the involvement of other participants, if those individuals are being tried in separate actions, the minor’s role in the crime, and the minor’s impact in causing the losses.

The full opinion is available on the court’s website here: https://www4.courts.ca.gov/opinions/documents/A172959.PDF