The Supreme Court of Pennsylvania held that there is no liability when a minor furnishes alcohol to another minor who is subsequently injured due to intoxication.
Kapres v. Heller, 640 A.2d 888 (Pa. 1994).
Jason G. Bates,
Tort Law - Social Host Liability - Non-Liability of Minors,
Duq. L. Rev.
Available at: https://dsc.duq.edu/dlr/vol33/iss3/15