State v. Edelman

The primary issue presented in this case is whether a court has the authority to modify a restitution order entered under RCW 9.94A.142 to provide for payment to a victim’s estate after the victim has passed away. The State appeals the trial court’s orders dismissing its motion to sanction Elizabeth Edelman for noncompliance with a restitution order after the death of the named recipient and denying a motion to amend the order. We hold that a defendant’s restitution obligation does not automatically end when a victim dies and that the statutes permit the modification of a restitution order to…