State v. Hartke

The question here is whether extending juvenile jurisdiction retroactively to collect restitution violates the ex post facto prohibition of the federal and state constitutions. U.S. Const, art. I, § 9; Const, art. I, § 23. Juvenile restitution is imposed for the primary purposes of compensating victims, juvenile accountability, and juvenile rehabilitation. State v. Sanchez, 73 Wn. App. 486, 489, 869 P.2d 1133 (1994). Because restitution is not punishment, we conclude there has been no violation of the ex post facto clause. We also conclude that the failure of the court to extend juvenile…